- 2 -
Rules 180, 181, and 183.1 The Court agrees with and adopts the
Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined
deficiencies in petitioner's Federal income taxes for the taxable
years 1989 and 1992, as well as additions to tax and penalties
for negligence, as follows:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1989 $5,422 $1,263 $1,084
1992 39,312 9,268 7,862
The issues for decision are: (1) Whether petitioner is
entitled to gambling losses in the amounts of $29,978 and
$140,830 for 1989 and 1992, respectively; (2) whether petitioner
is liable pursuant to section 6651(a)(1) for additions to tax for
failure to timely file his income tax returns for 1989 and 1992;
and (3) whether petitioner is liable pursuant to section 6662(a)
for accuracy-related penalties for negligence for 1989 and 1992.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Miami Beach, Florida, at the time
that his petition was filed with the Court.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011