Albert J. and Helen R. Desantis - Page 3

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          against petitioner Helen R. DeSantis, said deficiencies and                 
          additions were resolved prior to trial.2                                    
               In her amended answer at docket No. 5766-90, respondent                
          asserted that the deficiencies in and additions to petitioner's             
          Federal income tax be increased by the following amounts:                   
                      Additions to Tax                                                
          Year   Deficiency   Sec. 6653(b)(1) Sec. 6653(b)(2)  Sec. 6661              
          1982    $64,429.86     $32,214.93          1         $16,106.97             
          1983     12,621.33       6,310.67          1           3,154.83             
          1984  1,066,763.88     533,381.94          1         266,691.47             
          1   50 percent of the interest due on the deficiency.                       
               The increases to the deficiencies in and additions to tax              
          are based upon respondent's claim that petitioner fraudulently,             
          and with the intent to evade tax, failed to report income in the            
          additional amounts of $128,860.71, $25,237.66, and $2,133,528.76            
          on his 1982, 1983, and 1984 returns, respectively.  Therefore,              
          the total deficiencies in and additions to tax in dispute with              
          respect to docket No. 5766-90 are as follows:                               
                         Additions to Tax                                             
          Year    Deficiency   Sec. 6653(b)(1)  Sec. 6653(b)(2)  Sec. 6661            
          1982    $393,679.86    $196,839.93          1          $98,419.97           
          1983   1,338,683.33     669,341.67          1          334,670.83           
          1984   1,386,577.88     693,288.94          1          346,644.47           
          1    50 percent of the interest due on the deficiency                       



          2  Respondent, in a second notice of deficiency dated Apr.                  
          9, 1991, determined additions to tax under secs. 6653(b)(1) and             
          (2) and 6661 against petitioner Helen R. DeSantis.  A timely                
          petition was filed at docket No. 13108-91.  Respondent conceded             
          the adjustments in this notice of deficiency.                               




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