- 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