Michael London - Page 2

                                                  - 2 -                                                 
                                     Additions to Tax                                                   
               Year Deficiency Sec. 6653(b)(1)  Sec. 6653(b)(2)  Sec. 6661                              
               1983  $148,421        $74,211             50% of the   $37,105                           
                                                         interest due                                   
                                                         on $148,421                                    
               1985   105,160        52,580              50% of the                                     
                                                         interest due                                   
                                                         on $105,160   26,290                           

               All section references are to the Internal Revenue Code as                               
               in effect during the years in issue.                                                     
                      After concessions, the issues for decision are:                                   
               (1) Whether Mr. London's deposition in a prior proceeding                                
               is admissible in evidence on the ground that he is                                       
               unavailable as a witness within the meaning of rule 804(a)                               
               of the Federal Rules of Evidence due to his refusal to                                   
               answer any of the questions put to him on Fifth Amendment                                
               grounds; (2) whether the tapes and transcripts from the                                  
               electronic surveillance conducted at Mr. London's business                               
               and the evidence derived therefrom are admissible in                                     
               evidence; (3) whether petitioners failed to report income                                
               in 1983 and 1985, as determined by respondent using the net                              
               worth method of reconstructing income; (4) whether                                       
               petitioners are liable for additions to tax for fraud under                              
               section 6653(b)(1) and (2) for 1983 and 1985; (5) whether                                
               petitioners are liable for additions to tax for substantial                              
               understatement of liability under section 6661(a) for 1983                               
               and 1985; (6) whether Mrs. London intended to file a joint                               





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