Robert B. Keenan - Page 2

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          Docket No. 13925-95:                                                        
                Additions to Tax                                                      
          Year       Deficiency       Sec. 6651(a)(1)    Sec. 6654(a)                 
          1992        $19,393             $4,848             $846                     

          Docket No. 19874-96:                                                        
                Additions to Tax                                                      
          Year       Deficiency       Sec. 6651(a)(1)     Sec. 6654(a)                
          1988        $73,559             $16,120            $4,059                   
          1990        141,784              33,176             8,670                   
          1991         20,822               4,585             1,040                   

          Docket No. 15455-97:                                                        
                Additions to Tax                                                      
          Year       Deficiency       Sec. 6651(a)(1)     Sec. 6654(a)                
          1989        $70,821           $13,734.00         $2,871.00                  
          1993         16,114             4,028.50            675.11                  
          1994         17,361             4,340.25            894.53                  
               Following concessions by the parties,2 the issues for decision         
          are: (1) Whether assessment of deficiencies and additions to tax            
          for petitioner's 1989 tax year is barred by the expiration of the           
          statutory period of limitations; (2) whether petitioner had taxable         
          income in 1988 in the amount of $205,000 as a result of a purported         
          distribution from his individual retirement account (IRA) at U.S.           

               2    On the basis of information from third parties                    
          indicating that they had made payments of income to petitioner,             
          respondent determined that petitioner failed to report such                 
          income.  Petitioner conceded virtually all of the unreported                
          income adjustments relating to said payments.                               
               Respondent conceded petitioner's entitlement to certain                
          losses arising from forced Internal Revenue Service (IRS) tax               
          sales in 1993.                                                              




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