Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 2

                                        - 2 -                                         

          Petitioners Joan Walters and Henry Gherman:                                 
                                 Additions to Tax                                     
          Sec.         Sec.          Sec.         Sec.      Sec.                      
          TYE   Deficiency  6653(a)(1)  6653(a)(1)(a)  6653(a)(1)(B) 6653(a)(2)   6661
          1982     $3,191       $160          -          $28,318          1          -
          1984    769,999     38,500          -             -           1      $192,500
          1985    679,323     33,966          -             -           1       169, 831
          1986    792,359        -         $39,618          1           -       198,090
          150 percent of the interest due on the entire deficiency in income tax.     
          Petitioner Henry Gherman:                                                   
                                 Additions to Tax                                     
          Sec.       Sec.          Sec.         Sec.         Sec.                     
          TYE   Deficiency  6651(a)(1)  6653(a)(1)  6653(a)(1)(A) 6653(a)(1)(B)   6661
          1987   $566,350        -           -         $28,318       1           $141,588
          1988    461,477    $115,369     $24,828          -         -          115,369
          150 percent of the interest due on the entire deficiency in income tax.     
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.  Respondent concedes the deficiency and             
          additions to tax for taxable year ended 1982.  Accordingly,                 
          references to the years in issue hereinafter refer to years ended           
          1984 through 1988.                                                          
               The issues for decision are:                                           
               (1)  Whether petitioners for taxable years ended 1984                  
          through 1986 and petitioner Henry Gherman for taxable years ended           
          1987 and 1988 omitted income in the amounts determined by                   
          respondent, or in some other amounts.  We hold that they omitted            
          income to the extent determined herein.                                     






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011