- 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