- 2 - Respondent determined that petitioner received $258,542 in unreported income in 1989 but now concedes that the amount is $218,542. Petitioner contends that $200,000 of this amount was nontaxable. After concessions, we must decide: 1. Whether $200,000 petitioner received in wire transfers from investors and used for personal purposes in 1989 is taxable as income to him. We hold that it is. 2. Whether petitioner is liable for the addition to tax under section 6651(a)(1) for failure to timely file his 1989 income tax return. We hold that he is. 3. Whether petitioner is liable for the accuracy-related penalty under section 6662(a) for negligence. We hold that he is. Section references are to the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioner Petitioner lived in Merritt Island, Florida, when he filed his petition in this case. B. Petitioner's Business Activities In 1989, petitioner developed real estate through various entities, including partnerships, corporations, joint ventures, and sole proprietorships. World Golf & Tennis, Ranches of Daytona Beach, and Wildbahn and Clam were three of his projectsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011