Jerry S. Payne - Page 2

                                        - 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