Edward Nathan Levine - Page 2

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          1 50 percent of the interest due on $2,294,259.                             
               By an amendment to answer, respondent asserts as his primary           
          position an increase in the determination of deficiency for 1988            
          and additions to tax for fraud as follows:                                  
                                             Additions to Tax                         
                              Sec.      Sec.      Sec.      Sec.                      
               Year Deficiency  6653(b)(1)(A)  6653(b)(1)6653(b)(1)(B)   6654                
               1987    $2,294,259     $1,720,694       --1        $123,913              
               1988 110,500   --        $82,875   --        6,573                     
               1 50 percent of the interest due on $2,294,259.                        
               All section references are to the Internal Revenue Code in             
          effect for the taxable years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure, unless                
          otherwise indicated.  All dollar amounts are rounded to the                 
          nearest dollar, unless otherwise indicated.                                 
               The issues for decision are:  (1) Whether petitioner had               
          unreported income of $5,948,020 and $367,360 in 1987 and 1988,              
          respectively.  We hold he did.  (2) Whether petitioner is liable            
          for additions to tax for fraud for 1987 and 1988, or, in the                
          alternative, whether petitioner is liable for the additions to              
          tax for failure to file tax returns for 1987 and 1988, and for              
          negligence.  We hold petitioner is liable for the additions to              
          tax for fraud for 1987 and 1988.  (3) Whether petitioner is                 
          liable for self-employment tax of $5,387 and $5,859 in 1987 and             
          1988, respectively.  We hold he is.  (4) Whether petitioner is              
          liable for the additions to tax pursuant to section 6654 for                
          failure to pay estimated income tax.  We hold he is.                        






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