- 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 other
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011