Shigenori Kudo and Motomi Kudo, et al. - Page 6

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               (1)  Whether petitioners Yoshinori Takao (Yoshinori) and               
          Akiko Takao (Akiko) (hereinafter collectively referred to as the            
          Takaos) received unreported taxable income in the amounts of                
          $122,483, $75,421, $114,935, and $109,094 for 1988, 1989, 1990,             
          and 1991, respectively, as shown by unexplained bank deposits               
          made by them during those years.  We hold that they received                
          unreported income in the amounts decided herein.                            
               (2)  Whether the Takaos received additional unreported                 
          income in the amounts of $9,000 and $58,320 for 1988 and 1989,              
          respectively, as shown by certain cash purchases made by them               
          during those years.  We hold that they received additional                  
          unreported income in the amounts decided herein.                            
               (3)  Whether the Takaos are entitled to investment interest            
          deductions in the amounts of $55,320, $38,355, $30,000, and                 
          $13,850 for 1988, 1989, 1990, and 1991, respectively.  We hold              
          that they are not.                                                          
               (4)  Whether the Takaos are liable for an addition to tax              
          for late filing under section 6651(a) for 1988.  We hold that               
          they are.                                                                   
               (5) Whether the Takaos are liable for an addition to tax for           
          negligence under section 6653(a)(1) for 1988 and accuracy-related           
          penalties for negligence under section 6662(a) for 1989, 1990,              
          and 1991.  We hold that they are.                                           








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