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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined the following
deficiencies and accuracy-related penalties with respect to the
Federal income tax of petitioner, John R. Boone, Jr., for the
taxable years 1989 and 1990:
Penalties
Year Deficiency Sec. 6662(a)
1989 $11,775 $2,415
1990 32,389 6,478
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions by petitioner, the issues remaining for
decision are: (1) Whether respondent is barred by the expiration
of the 3-year period of limitations of section 6501(a) from
assessing and collecting deficiencies in petitioner's Federal
income tax for 1989 and 1990; and, if respondent is not so
barred; (2) whether petitioner understated his income tax in the
amounts determined by respondent in the notice of deficiency for
the years in issue; and (3) whether unreported bank deposits and
cash expenditures made by petitioner in 1989 and 1990 constitute
self-employment income subject to tax under section 1401 for
those years; and (4) whether petitioner is liable for accuracy-
related penalties for negligence pursuant to section 6662(a) for
1989 and 1990.
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