Marco Deplano - Page 2

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               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               The issues for decision are: (1) Whether petitioner is                 
          liable for additions to tax under section 6653(a)(1) and (2).  We           
          hold that he is. (2) Whether petitioner is liable for an addition           
          to tax under section 6661(a).  We hold that he is.                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.                                      
               At the time the petition was filed, petitioner resided in              
          New York, New York.                                                         
               Petitioner received a bachelor of science degree from                  
          Trinity University of Texas in 1978.  In 1983, petitioner was               
          employed as an art director by Marsteller Inc. and also did                 
          graphic design and advertising work for Gorman-Glassberg, Inc.              
          Also during 1983, petitioner ran a sole proprietorship providing            
          freelance work in the field of graphic design and advertising               
          from which he reported gross receipts of $49,983 and a net profit           
          of $23,190.  Petitioner was 26 years old in 1983.                           
               Petitioner's return was prepared by Nicholas J. Coscia, an             
          accountant with Coscia and Amsterdam.  At this time, Mr. Coscia             






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