Robert T. Schirle - Page 3

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               (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.                               



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