Greg R. Vinikoor and Melissa D. Vinikoor - Page 20

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          relates to the $20,306 listed as owed on their original return.             
          Petitioners further stipulated that they are liable for an                  
          addition to tax pursuant to section 6651(a)(1) for 1990 insofar             
          as it relates to their basis in their Price Co. stock if we found           
          that the shares transferred to petitioners by Drachman on October           
          30 and December 10, 1987, were not bona fide loans.  We have so             
          found.  Petitioners did not stipulate their liability for an                
          addition to tax pursuant to section 6651(a)(1) insofar as it                
          relates to the additional tax liability acknowledged on their               
          amended return filed April 20, 1992.                                        
               The Commissioner's determinations are presumed correct, and            
          the taxpayer bears the burden of proving otherwise.  Rule 142(a);           
          Welch v. Helvering, 290 U.S. at 115.  Some of petitioners'                  
          liability for additions to tax pursuant to section 6651(a)(1) for           
          1990 has been stipulated, and petitioners have failed to meet               
          their burden as to the other liability.                                     
               Accordingly, respondent's addition to tax pursuant to                  
          section 6651(a)(1) is sustained.                                            
               For the foregoing reasons,                                             
                                                  Decision will be entered            
                                             under Rule 155.                          










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