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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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