2
Accuracy-related
Addition to tax penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $57,187 $15,064 $11,437
1992 129,170 19,577 25,834
After concessions,1 the issues for decision are:
1. Whether the Court's denial of petitioner's second
motion for a continuance was proper. We hold that it was.
2. Whether petitioner's documentary evidence was properly
excluded from evidence after he failed to comply with the Court's
orders and his agreement with respondent to identify in writing
and exchange that evidence with respondent. We hold that it was.
3. Whether petitioner may deduct more Schedule C and
Schedule E expenses for 1991 and 1992 than respondent allowed.
We hold that he may not.
4. Whether petitioner may deduct investment interest
expense for 1992. We hold that he may not.
5. Whether petitioner failed to report $18,795 in capital
gain for 1992. We hold that he did.
6. Whether petitioner failed to report gain of $122,000
from the sale of the Brentwood Apartments in 1992. We hold that
he failed to report gain of $118,000.
1 Petitioner concedes that respondent properly disallowed
$9,883 of Olga Schaefer's Schedule C business expenses for 1991,
and that he failed to report interest and dividend income of $936
for 1992.
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