Thomas L. and Laura L. Gordon - Page 2

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               1 50 percent of the interest computed on $18,246 at the time           
          of assessment and/or payment of tax.                                        
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               The issues remaining for decision are:  (1) Whether                    
          petitioners failed to report income from thefts on their 1986               
          return; (2) whether petitioners are liable for the addition to              
          tax for fraud; and (3) whether petitioners are liable for the               
          addition to tax for substantial understatement of liability.                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time their petition was filed, petitioners were husband and wife            
          and resided in San Dimas, California.                                       
               Petitioners were married in November 1983.  Petitioner                 
          Laura L. Gordon (Mrs. Gordon) was married to Alexander P.                   
          Sandoval (Sandoval) from 1975 to 1982.  Mrs. Gordon received                
          child support payments in bimonthly amounts of $136 during 1985             
          and 1986 as a result of her divorce from Sandoval.                          
               Petitioners filed a Form 1040, U.S. Individual Income Tax              
          Return, for 1986 showing $42,309 as their adjusted gross income.            








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