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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.
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