Joseph L. Guillo, Sr. - Page 2

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          petitioner's liabilities for Federal income and self-employment             
          taxes on unreported income and for additions to tax under                   
          sections 6651 and 6654.                                                     
               Respondent determined deficiencies and additions to tax with           
          respect to petitioner's Federal income and self-employment taxes,           
          as follows:                                                                 

                                        Additions to tax                              
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6654                 
               1986      $16,505        $4,126              $  796                    
               1987      20,009              5,002     1,080                          
               1988      17,234              4,309     1,102                          
               1989      20,522              5,131          1,389                     
               1990      15,886              3,972          1,045                     

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  All figures are rounded.                                        
               When the petition was filed, petitioner resided in Sedona,             
          Arizona.                                                                    
               For 1986 through 1990, petitioner failed to file Federal               
          income tax returns.  During audit, respondent reconstructed                 
          petitioner's taxable income for the years in issue using the bank           
          deposits method.  On October 10, 1995, respondent issued to                 
          petitioner a notice of deficiency with the above adjustments.               
               On November 20, 1995, petitioner timely filed a petition for           
          the years in issue.  On January 22, 1996, respondent timely filed           





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