-2-
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)1 6653(b)(1)(B) 6653(b)(2) 6661
1983 $101,744 $50,872 2 $25,436
1984 21,946 10,973 2 5,487
1985 7,233 3,617 2 1,808
1986 34,075 25,556 2 8,519
1987 7,387 5,540 2 1,847
1 Sec. 6653(b)(1)(A) for 1986 and 1987.
2 Fifty percent of the interest due on the underpayment due to fraud.
After concessions,1 the issues for decision are:
1. Relating to respondent's use of the net worth method:
a. Whether respondent's determination was arbitrary.
We hold that it was not.
b. Whether respondent adequately investigated leads
relating to petitioners' cash hoard. We hold that respondent
did.
2. Relating to petitioners' cash on hand on December 31,
1982, 1983, 1984, 1985, 1986, and 1987:
a. Whether petitioners had $140,000 in cash on
December 31, 1982, as respondent contends; more than $660,000, as
petitioners contend; or some other amount. We find that
petitioners had $279,000 in cash on December 31, 1982.
1 Respondent concedes that for 1983 to 1987, petitioners may
deduct additional depreciation of $3,631, $9,255, $11,902,
$11,736, and $11,736, respectively, on their property at 3600
Glenstone Avenue, Springfield, Missouri. Respondent also
concedes that petitioners had a $896 capital gain in 1986.
Respondent concedes that $9,000 that respondent had determined
was taxable in 1986, is not taxable. Respondent concedes that in
respondent's calculation of their unreported income, petitioners'
1987 personal expenses are overstated by $50.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011