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Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1987 $46,761 $11,690 $2,525
1988 52,610 13,071 3,340
1989 54,367 13,592 3,678
1990 31,418 7,801 2,054
1991 17,883 4,471 1,023
1992 43,839 10,957 1,909
After concessions, the issues for decision are: (1) Whether
bank deposits totaling $574,0941 constitute income to petitioner,
and (2) whether petitioner is liable for additions to tax
pursuant to sections 6651(a)(1) and 6654(a).2
1Respondent has conceded the following reductions to
petitioner's self-employment income as determined in the notice
of deficiency:
Per Notice of Corrected
Year Deficiency Reduction Amount
1987 $116,177 ($300) $115,877
1988 158,626 (29,099) 129,527
1989 153,169 (14,414) 138,755
1990 88,044 (20,739) 67,305
1991 49,773 (6,781) 42,992
1992 101,022 (21,384) 79,638
Total $666,811 ($92,717) $574,094
Respondent also conceded that petitioner's capital gains, as
determined in the notice of deficiency for 1990, should be
reduced by $765.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011