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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 projects
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