Gerald Hickman - Page 6

                                        - 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