John R. Boone, Jr. - Page 2

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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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