Stanley J. Zaban and Shirley A. Zaban - Page 2

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                           Additions to Tax & Penalties                               
          Sec.         Sec.            Sec.          Sec.      Sec.   Sec.    Sec.    
          Year  Deficiency  6651(a)(1)  6653(b)(1)(A)  6653(b)(1)(B)  6653(b)(1)   6661   6663  6662(b)(2)
          1986  $44,245        ---        $33,184            1            ---     $11,061  ---     ---
          1987   71,567        ---         53,675            1            ---      17,892  ---     ---
          1988   26,976        ---          ---             ---         $20,232     6,744  ---     ---
          1989   75,714      $14,892        ---             ---           ---       ---  $56,786   ---
          1990   44,331        ---          ---             ---           ---       ---    ---    $8,866
               1     50 percent of the interest payable under sec. 6601 on the portion of
          the underpayment attributable to fraud.                                     
          As an alternative to the fraud additions to tax and penalty,                
          respondent determined additions to tax for negligence or disregard          
          of rules or regulations pursuant to section 6653(a)(1)(A) and (B)           
          for 1986 and 1987 and section 6653(a)(1) for 1988 and an accuracy-          
          related penalty pursuant to section 6662 for 1989.                          
               The 1986 through 1989 deficiencies arose out of unreported             
          income from petitioner Stanley J. Zaban's (Mr. Zaban) illegal               
          gambling and bookmaking activities and skimming from his legitimate         
          business activities, as well as respondent's disallowance of                
          certain miscellaneous expense deductions for 1987 and 1988.  The            
          1990 deficiency arose out of respondent's disallowance of both a            
          mortgage interest deduction and a deduction for funds forfeited to          
          the Baltimore County Police Department after the funds were seized          
          in the execution of search warrants as proceeds from Mr. Zaban's            
          illegal activities.                                                         












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