- 30 -
* * * * * * *
It is determined that you realized additional
income [for 1985] in the amount of $213,120.00
because the comparison of all known expenditures
with all known receipts, as shown on Exhibit A
attached hereto, has established an understate-
ment of income. Since you failed to include
such additional income on your income tax return,
taxable income is increased in the amount of
$213,120.00.
Based thereon, respondent computed increases in tax of
$148,421 and $105,160 for 1983 and 1985, respectively.
Respondent also determined with respect to 1983 and 1985
that petitioners are liable for the additions to tax for
fraud under section 6653(b)(1) and (2), and the addition
to tax for substantial understatement of liability under
section 6661.
OPINION
Admissibility of Mr. London's Deposition in the Wrongful
Levy Suit
At trial, Mrs. London called her husband to testify as
a witness. In response to each of the questions put to him
by Mrs. London's attorney and by the Court, Mr. London
invoked his Fifth Amendment privilege against self-
incrimination and refused to answer the question. Counsel
for Mrs. London then offered into evidence the deposition
of Mr. London taken during the wrongful levy suit,
Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 NextLast modified: May 25, 2011