- 3 - gross receipts from his tavern business during the years in issue; (b) petitioner is entitled to deduct certain business expenses in excess of the amount allowed by respondent for the years in issue; (c) petitioner is liable for additions to tax for fraud under section 6653(b)(1)(A) and (B) for 1987 and under section 6653(b) for 1988; (d) petitioner is liable for penalties for fraud under section 6663 for 1989 and 1990; and (e) petitioner is liable for additions to tax for substantially understating income tax under section 6661 for 1987 and 1988. FINDINGS OF FACT Some of the facts have been stipulated for trial pursuant to Rule 91. The parties' stipulations of fact are incorporated herein by reference and are found as facts in the instant case. Petitioner resided in Jamestown, New York, at the time he filed his petition. Petitioner filed timely Federal income tax returns (returns) for all years in issue. Background During the years in issue, petitioner owned and operated the Bullfrog Hotel (Bullfrog) in Jamestown, New York. The Bullfrog, located on the Chautauqua River in the industrial section of Jamestown, consists of a 22-room hotel and a tavern. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011