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All section references are to the Internal Revenue Code as
in effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
The issues for decision are whether, for the years 1987 and
1988, petitioner had unreported embezzlement income, and whether
he is liable for additions to tax for his failures to file income
tax returns and make estimated tax payments. We hold that
petitioner had unreported embezzlement income, and that he is
liable for the additions to tax.1
FINDINGS OF FACT
We find and incorporate the stipulated facts and exhibits.
Petitioner resided in Lakeland, Florida, at the time he filed his
petition.
Petitioner is a graduate of Emory University School of Law
and prior to 1987 had practiced law in the State of Florida for
22 years. In the early 1970's, petitioner became acquainted with
the family of Zelda Willey Putman (Mrs. Putman), who lived in his
neighborhood. Over the years petitioner became a close friend of
the Putmans; Mrs. Putman's daughters called petitioner "Uncle
Bill".
1 Respondent has conceded that petitioner's embezzlement
income for 1988 is slightly less than the amount determined in
the statutory notice of deficiency.
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