Albert J. and Helen R. Desantis - Page 2

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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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