- 6 - of judgment against petitioner, sentencing petitioner to community confinement and probation. In addition, the District Court's Order of Judgment required petitioner to make immediate restitution to the Internal Revenue Service in the total amount of $36,276. The restitution amount is based on the Government witness's testimony of petitioner's tax liability for 1986 through 1988. On or around December 27, 1993, petitioner paid the ordered restitution in full. The judgment of the District Court is final. Subsequently, respondent determined in the notice of deficiency that petitioner received income in the amounts of $30,252, $49,324, and $56,638, respectively, for 1986 through 1988. Based on those amounts, respondent's deficiency determinations for 1986 through 1988 are $10,690, $17,884, and $19,350, respectively. The total deficiency for all 3 years is $47,924, an $11,648 difference from the tax liability presented to the District Court and the District Court's ordered restitution payment. The difference in the tax liability calculation submitted to the District Court and respondent's deficiency determination stems from respondent's disallowance of certain capital losses and itemized deductions. These disallowances result in positive adjustments to the taxable income figures presented to the District Court.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011