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Additions to Tax and Penalties
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6653(b)(1) 6653(b)(1)(B) 6663
1987 $5,115 $5,802 - 1 -
1988 10,058 - $7,544 - -
1989 16,448 - - - $12,336
1990 15,437 - - - 11,578
1 In addition, with respect to the taxable year 1987, respondent has
determined an addition to tax pursuant to sec. 6653(b)(1)(B) in an amount
equal to 50 percent of the interest due on the underpayment attributable to
fraud.
The issues for our consideration are: (1) Whether
petitioner was required to report as income money received from
two restaurants during the years at issue; (2) whether petitioner
failed to report dividend income from jointly held mutual funds
for 1988, 1989, and 1990; (3) whether petitioner received $2,000
in unreported income as a result of preparing a U.S. Individual
Income Tax Return, Form 1040, in the name of Chris Arias;
(4) whether respondent properly denied petitioner's claimed
capital losses of $2,858, $3,000, $3,000, and $2,400 for 1987,
1988, 1989, and 1990, respectively; (5) whether petitioner was
entitled to claim his mother as a dependent on his 1990 Federal
income tax return; (6) whether petitioner was entitled to certain
claimed itemized deductions for 1987, 1988, 1989, and 1990,
respectively; and (7) whether any part of any underpayment of tax
on petitioner's returns for the taxable years 1987 through 1990
was due to fraud.
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Last modified: May 25, 2011