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a basketball issue in the winter. In 1989, he published three
editions--fall, winter, and spring.
During the period 1989, through 1994, petitioner sold
advertising in SIPS to local businesses at the following rates:
$55 for a business card-sized advertisement; $85 for one-sixth
page; $120 for one-quarter page; $200 for one-half page; and $360
for a full page.
During 1990 and 1991, petitioner derived revenue in the
amounts of $50,710 and $44,125, respectively, from selling
advertising in SIPS. Of the amounts so derived, $25,140 and
$20,895 were not reported on petitioner’s income tax returns for
1990 and 1991, respectively. Petitioner understated his taxable
income on his tax returns for 1990 and 1991 in the amounts of
$30,385 and $26,670, respectively. Petitioner understated his
income tax liabilities on his tax returns for 1990 and 1991 in
the amounts of $11,065 and $6,882, respectively.
Petitioner did not file income tax returns for 1989, 1992,
1993, and 1994. During 1989, 1992, 1993, and 1994, petitioner
derived revenue in the amounts of $77,175, $52,485, $53,575, and
$59,780, respectively, from selling advertising in SIPS.
Petitioner failed to report taxable income for 1989, 1992, 1993,
and 1994, in the amounts of $57,505, $31,885, $30,477, and
$36,551, respectively. As a result of not filing income tax
returns for 1989, 1992, 1993, and 1994, petitioner understated
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