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1984 and 1985 and under sec. 6653(b)(1)(A) and (B),
I.R.C., for 1986 and 1987.
Held, further, P is liable for additions to tax
for substantial underpayment of tax liability under
sec. 6661, I.R.C., for 1984, 1985, 1986, and 1987.
Robert L. Gallaway, for petitioner.
Margaret C. Tinagero, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Thomas G. Roots petitioned the Court to
redetermine respondent's determination of the following Federal
income tax deficiencies and additions1 thereto:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6661
1984 $30,759 $15,380 --- $7,690
1985 36,545 18,272 --- 9,136
1986 5,166 --- $3,875 1,292
1987 30,816 --- 23,455 7,704
Following concessions, we must decide:
1. Whether petitioner's currency deposits to his bank
account for 1984, 1985, 1986, or 1987 are taxable deposits. We
1 For petitioner's 1984 and 1985 taxable years, respondent
also determined that if the addition to tax under sec. 6653(b)(1)
applies, the addition to tax under sec. 6653(b)(2) will apply in
an amount equal to 50 percent of the interest payable with
respect to the portion of the underpayment which is attributable
to fraud. For petitioner's 1986 and 1987 taxable years,
respondent also determined that if sec. 6653(b)(1)(A) applies,
sec. 6653(b)(1)(B) will apply in an amount equal to 50 percent of
the interest payable with respect to the portion of the
underpayment which is attributable to fraud.
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