Charles McHan and Martha McHan - Page 4

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          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.                                     





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