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(7) whether petitioner is entitled to a dependency exemption
for Anupam Tandon (Anupam) in 1986;
(8) whether petitioner is liable for additional self-
employment tax in 1986 and 1987;
(9) whether petitioner is liable for the additions to tax
for fraud for 1985, 1986, 1987, and 1988 to the extent there is
any unreported medical practice and/or rental income;
(10) whether petitioner is liable for the additions to tax
for negligence for 1986, 1987, and 1988; and
(11) whether petitioner is liable for the additions to tax
for a substantial understatement for 1985, 1986, 1987, and 1988.
Finally, if we decide that petitioner did not fraudulently
fail to report income in 1985, 1986, 1987, and 1988, we must
decide whether the periods of limitations for assessing taxes for
these years have expired.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Mayfield Heights, Ohio, at the time he filed his petition.
Petitioner prepared his own tax returns for the years in issue.2
Petitioner has three children--Manoj, Harsh, and Parag.
During the years in issue, Manoj was a teenager. Guru Prasad
2 Unless otherwise indicated, all descriptions refer to the
1985, 1986, 1987, and 1988 tax years.
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