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the years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
After concessions by the parties, the issues remaining for
decision are:
For 1988, whether the statute of limitations bars assessment
and, if not, whether petitioners had unreported income from
various real estate transactions, unemployment compensation, and
unexplained bank deposits and whether they are entitled to
deductions relating to their taxi business.
For 1990 and 1991, whether petitioners had various items of
unreported income and whether they are entitled to deductions
relating to a vehicle resale business and a business school.
For all years, whether petitioners are liable for the
additions to tax and penalties determined by respondent.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners, Leo Goldberg (petitioner) and Alla Goldberg
(Mrs. Goldberg), were married and resided in Orange County,
California, at the time they filed their petition.
Petitioner immigrated to the United States from the Soviet
Union in 1977. Petitioner received a degree in engineering from
Moscow University, and he earned an M.B.A. from Pepperdine
University in December 1987. Petitioner has been involved, at
least to some extent, with real estate since 1986. He became
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