-55- Thus, (1) petitioners' gain on the transaction is $953 more than the amount determined in the notice of deficiency, but (2) because of the 60-percent exclusion, petitioners' adjusted gross income from the transaction is $5,619 less than the amount determined in the notice of deficiency. Petitioners failed to file a timely 1981 tax return. In fact, petitioners' 1981 tax return was filed after the notices of deficiency were issued in the instant case. In their late-filed 1981 tax return, petitioners acknowledged a tax liability of $5,501. Our findings show that petitioners' 1981 income subject to tax is far greater than what they reported on their 1981 tax return. There is no indication of offsetting deductions or credits. We conclude, and we have found, that respondent has shown by clear and convincing evidence that petitioners had an underpayment of tax for 1981. (3) 1982 In the notices of deficiency for 1982, respondent determined that petitioners had unreported income from (1) Random Processing Services, Inc., (2) SSI, (3) the FE Trust, and (4) Maximum Management, and had unreported capital gain from the sale of SSC. Pursuant to the parties' stipulation, we have found that in 1982 two checks totaling $15,000 were drawn on the Random Processing Services' bank account to Monica. We have found thatPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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