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Petitioner Donald J. Miravalle
Additions to Tax Under
Tax Year Deficiency Sec. 6653(b) Sec. 6654
1982 $12,402 1$6,201 --
1983 74,586 137,293 $10,009
1 Plus 50 percent of the interest due on the deficiency.1
Petitioner Lillian Joy Miravalle
Additions to Tax Under
Tax Year Deficiency Sec.6653(b) Sec. 6654
1982 $12,402 1$6,201 --
1983 74,586 137,293 $10,009
1 Plus 50 percent of the interest due on the deficiency.1
The issues for decision are whether petitioners:
(1) Had unreported income derived from Schedule C gross
receipts and expenses for the taxable years 1982 and 1983;
(2) Had unreported interest income in 1982 and 1983;
(3) Are liable for the additions to tax for fraud under
section 6653(b)(1) and (2)1 for 1982 and 1983; and
(4) Are liable for the addition to tax under section 6654
for 1983.
This case was submitted fully stipulated under Rule 122.
Certain facts and exhibits are deemed stipulated by the granting
of respondent's motion pursuant to Rule 91(f). The agreed facts
1 Unless otherwise indicated, all statutory references are
to the Internal Revenue Code in effect for the years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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Last modified: May 25, 2011