- 2 -
1990 79,843 --- 15,969
In the answer, respondent asserted that the additions to tax and
the penalties with respect to petitioner's Federal income tax
should be as follows:
Additions to Tax Penalties
Sec. Sec. Sec. Sec.
Year 6653(a)(1) 6653(b)(1) 6662(a) 6663(a)
1988 $62 $49,424 --- ---
1989 --- --- $829 $59,879
1990 --- --- 368 58,502
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
After concessions,1 the issues for decision are:
(1) Whether petitioner underreported his medical practice
gross receipts for 1988, 1989, and 1990 in the amounts of
$50,292, $58,971, and $67,488, respectively;
(2) whether petitioner is entitled to deduct various costs
related to real property as ordinary and necessary expenses paid
or incurred during the taxable year in carrying on a trade or
business;
(3) whether petitioner is liable for the addition to tax for
1 Respondent concedes that petitioner substantiated
Schedule A medical expenses in the amount of $3,377 for 1990.
Petitioner concedes that he understated his income in the amounts
of $44,405 and $58,669 for 1989 and 1990, respectively.
Petitioner further concedes that he is not entitled to alimony
deductions for 1988, 1989, and 1990.
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