- 2 - Docket No. 980-95 Additions to Tax Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661 1987 $172,310 $128,693 * $43,078 * 50 percent of interest payable under sec. 6601 with respect to portion of underpayment attributable to fraud. Docket No. 26812-95 Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec.6653(b)(1) Sec. 6661 1988 $653,048 $15,233 $3,047 $444,087 $163,262 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The primary issues for decision are: (1) Whether petitioner received legal fees and other income that he did not report on his Federal income tax returns; (2) the value of stock petitioner received in September of 1988 as income; (3) whether for 1988 petitioner is to be charged with discharge of indebtedness income; (4) whether for 1988 a corporation petitioner controlled made a valid S election; (5) whether for 1987 and 1988 petitioner is entitled to certain claimed deductions; and (6) whether for 1987 and 1988 petitioner is liable for the fraud addition to tax. Because of the inadequacy of petitioner’s books and records, respondent used a combination of the specific item and bank deposits methods of proof in determining significant increases to petitioner’s income over that reported on petitioner's income tax returns. Respondent also disallowed claimed deductions, made otherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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