William Henry Sundel - Page 2

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                                      Additions to Tax                                
             Deficiency   Sec. 6653(b)(1)  Sec. 6653(b)(2)  Sec. 6661(a)              
             $1,581,128      $790,564             1       $395,282                    
                  1Plus 50 percent of the interest payable under sec.                 
             6601 with respect to the portion of the underpayment which               
             is attributable to fraud.                                                

             Unless stated otherwise, all section references are to the               
             Internal Revenue Code as in effect for 1983.                             
                  After concessions, the issues remaining for decision                
             are:  (1) Whether, and to what extent, petitioner realized               
             unreported income in 1983 from the sale of marijuana; (2)                
             whether petitioner is liable for self-employment tax on                  
             the income earned from the sale of marijuana; (3) whether                
             petitioner is entitled to deduct expenses allegedly                      
             incurred during 1983 for legal services; (4) whether                     
             petitioner is liable for the additions to tax for fraud                  
             prescribed by section 6653(b)(1) and (2); (5) whether                    
             petitioner is liable for the addition to tax for                         
             substantial understatement of liability prescribed by                    
             section 6661(a); and (6) whether the period of limitations               
             on assessment and collection of tax prescribed by section                
             6501 expired before respondent issued the subject notice                 
             of deficiency.                                                           








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