- 4 - terest due on $305,762 est due on $69,635 The notice of deficiency includes an explanation of the adjustments which states in pertinent part: 1(A) It is determined that you received unreported income in the amounts of $1,311,670.00, $252,800.00 and $266,400.00, which was not reported on your income tax return for the years 1985, 1986, and 1987, respectively. Therefore, your taxable income is increased in the amounts of $1,311,670.00, $252,800.00 and $266,400.00 for the tax years ended December 31, 1985, December 31, 1986, and December 31, 1987, respectively. 1(B) It is determined that you are allowed the cost of sale of drugs in the amounts of $689,410.00, $159,525.00 and $65,490.00 for the years 1985, 1986, and 1987, respectively. Therefore, your taxable income is decreased in the amounts of $689,410.00, $159,525.00 and $65,490.00 for the tax years ended December 31, 1985, December 31, 1986, and December 31, 1987, respectively. 1(C) It is determined that you are allowed a net operating loss carryback in the amount of $0.00 rather than $122,352.00 and $180,687.00 as reported on your tax return for the years 1985 and 1986, respectively. Therefore, your taxable income is increased in the amounts of $122,352.00 and $180,687.00 for the tax years ended December 31, 1985 and December 31, 1986, respectively. The notice of deficiency states that the 1987 year is included in the notice for information purposes only. Petitioners invoked the Court's jurisdiction by filing a timely imperfect petition for redetermination, followed by an amended petition.4 Petitioner now moves for summary judgment with respect to the following issues: (1) The addition to tax for substantial 4 At the time that the petition was filed, petitioner was incarcerated in Estill, South Carolina.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011