Stanley L. Wade - Page 2

                                        - 2 -                                         
          Stanley L. and Janet Wade                                                   
          Docket No. 4703-94                                                          
                              Additions to Tax                                        
          Year    Deficiency Sec. 6653(b)(1)  Sec. 6653(b)(2)  Sec. 6661              
          1982     $131,240   $65,620             *              $32,810              
          1983      156,291   78,146                   *         39,073               
                    * 50 percent of interest due on portion of                        
                   underpayment attributable to fraud.                               

          Stanley L. Wade                                                             
          Docket No. 4623-94                                                          
                               Additions to Tax                                       
          Year    Deficiency   Sec. 6651(a)(1)    Sec. 6654                           
          1984   $133,837      $33,459     $8,415                                     

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After settlement of some issues, the issues for decision               
          are: (1) Whether petitioners are liable for the fraud and other             
          additions to tax, (2) whether petitioner may deduct $230,137 of             
          claimed business expenses, and (3) whether the period of                    
          limitations bars assessment of the tax deficiencies and additions           
          to tax for 1982, 1983, and 1984.                                            

                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  When the            
          petitions were filed, petitioners resided in Salt Lake City,                
          Utah.                                                                       



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011