T.C. Memo. 1997-561
UNITED STATES TAX COURT
JOHN BORETA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25943-93. Filed December 23, 1997.
Held: Petitioner did not adequately disclose on his
1988 Federal income tax return relevant facts regarding the
tax treatment of a claimed business interest expense
deduction. Petitioner is liable for an addition to tax
under sec. 6661, I.R.C.
Walter B. Thurmond and Charles B. Koerth, for petitioner.
Allan D. Hill, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: Respondent determined a deficiency of
$174,822 in petitioner’s Federal income tax for 1988 and
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