- 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