- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011