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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. The
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