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section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: In a notice of
deficiency dated December 27, 1989, respondent determined
deficiencies in and additions to petitioner Albert J. DeSantis'
(hereinafter petitioner) Federal income tax for 1982, 1983, and
1984:
Docket No. 5766-90
Additions to Tax
Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661
1982 $329,250 $164,625 1 $82,313
1983 1,326,062 663,031 1 331,516
1984 319,814 159,907 1 79,953
1 50 percent of the interest due on the deficiency.
The deficiencies and additions to tax are based upon
respondent's claim that petitioner fraudulently, and with intent
to evade tax, failed to report income in the amounts of $658,498,
$2,655,666, and $639,624 on his 1982, 1983, and 1984 returns,
respectively. While deficiencies in tax and additions to tax
under sections 6653(a)(1) and (2) and 6661 were determined
1 All section references are to the Internal Revenue Code
in effect for the years in issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
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