- 3 - (1) Whether petitioner failed to report income from his law practice in 1988, 1989, 1990, and 1991 in the amounts of $14,074, $68,648, $238,665, and $57,708, respectively;2 (2) whether petitioner failed to timely file his Federal income tax returns for the 1989 and 1991 tax years: (3) whether petitioner is liable for an addition to tax for fraud pursuant to section 6653(b) for the 1988 tax year; and (4) whether petitioner is liable for penalties for fraud pursuant to section 6663 for the 1989, 1990, and 1991 tax years. Finally, if we decide that petitioner did not fraudulently fail to report income, we must decide whether petitioner substantially omitted gross income in 1989 and 1990 so as to render section 6501(e) applicable, and, if not, whether the limitations periods for assessing taxes for those years have expired. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of facts and attached exhibits are incorporated 1(...continued) for additional self-employment taxes pursuant to sec. 1402 for each of the years in issue. This issue will be resolved under Rule 155 computations for any year in which we find that there are increases in petitioner's taxable income. 2 Respondent's determination of unreported income entails four components: (1) 162 cashed settlement checks, (2) a $3,000 cash deposit in 1989, (3) 12 checks deposited into a client trust account, and (4) a yearend ledger adjustment.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