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1983, and 1984 returns; (3) whether petitioner received $124,330
in income from Savko which was not reported on his 1983 return;
(4) whether petitioner is entitled to claim a deduction for
windfall profits tax withheld in the amount of $3,484 on his 1982
return; (5) whether petitioner is entitled to claim a bad debt
deduction in the amount of $2,516,224 on his 1984 return; (6)
whether respondent erroneously decreased reported 1984 income by
$1,933,600, as determined in the notice of deficiency, and
whether the proper decrease of reported income is $480,800, as
claimed by respondent in her amended answer; (7) whether
petitioner is liable for the additions to tax for fraud pursuant
to section 6653(b)(1) and (2) for the tax years ended 1982, 1983,
and 1984; and (8) whether petitioner is liable for the additions
to tax for substantial understatement of income tax for 1981,
1982 and 1983 under section 6661.
Procedural Background
These cases have a long history. The petition in docket No.
5766-90 was filed in March 1990. The first notice of trial was
issued in June 1991 setting this matter for trial in November
1991. The matter was continued based on a joint motion by the
parties. During 1992 through 1994, the matter was continued
three more times. In August 1993, we granted Aaron P.
Rosenfeld's and George N. Corey's motion to withdraw as counsel
for petitioner Albert J. DeSantis. When the matter was continued
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