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MEMORANDUM OPINION
HALPERN, Judge: By notice of deficiency dated October 17,
1991, respondent determined deficiencies in and additions to
petitioner's Federal income tax as follows:
Additions to Tax
Sec. Sec. Sec. Sec.
6653 6653 6653 6653Sec.
Year Deficiency (b)(1) (b)(1)(A) (b)(2) (b)(1)(B) 6661
1985 $4,770 $2,385 -- 50% of the -- --
interest due
on $4,770
1986 66,094 -- $49,571 -- 50% of the $16,524
interest due
on $66,094
1987 15,757 -- 11,818 -- 50% of the 3,939
interest due
on $15,757
The issues for decision are as follows:
1. Whether petitioner failed to report gross income from
drug-related activities for the years in question.
2. Whether petitioner is liable for additions to tax under
section 6661 for substantial understatement of income tax for
1986 and 1987.
3. Whether petitioner is liable for additions to tax under
section 6653(b) for fraud for each of the years in question.
4. Whether petitioner is liable for self-employment taxes
under section 1401 for each of the years in question.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
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