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Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661
1986 $34,031 $8,005 $1,712 1
$8,498
1987 26,867 6,118 1,348 2
6,202
1Fifty percent of the interest due on $34,031.
2Fifty percent of the interest due on $26,867.
For reasons discussed below, Mrs. Zuckerman is no longer a party
to this case. The issues for decision are:
(1) Whether petitioner had unreported embezzlement income
for 1986;
(2) whether deposits to certain bank accounts held by
petitioner represent unreported taxable income to him for 1987;
(3) whether petitioner failed to report interest and
dividend income for both taxable years at issue;
(4) whether petitioner is entitled to deductions for
Schedule A and Schedule C expenses in excess of the amounts
allowed by respondent; and
(5) whether petitioner is liable for additions to tax under
sections 6651(a)(1), 6653(a), and 6661.
We sustain respondent's determinations in respect of each of
the aforesaid issues to the extent specified herein.
1(...continued)
Internal Revenue Code in effect for the years at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011