Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 42

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                                    Year                                              
          1984        1985          1986        1987          1988                    
          Net amount                                                                  
          per CD Sch.  $1,575,000   $1,161,163   $1,752,537   $1,708,500   $1,525,300 
          Less:                                                                       
          Invoices                                                                    
          dated after                                                                 
          8/88           -0-          -0-          -0-          -0-         155,300   
          Interest                                                                    
          paid to CD                                                                  
          participants  304,864      282,452      406,917      484,548        -0-     
          Lesser of                                                                   
          W-2 wages or                                                                
          FIP's NOL     251,665      233,033      532,201      395,810      122,067   
          Unreported                                                                  
          income        1,018,471      645,678      813,419      828,142    1,247,933 
          For each of the years 1984 through 1987, the unreported income              
          exceeds 25 percent of the income reported on the return.                    
          Accordingly, we conclude that for each of those years the statute           
          of limitations does not bar the assessment of the deficiency or             
          additions to tax.                                                           
          Addition to Tax for Negligence                                              
               Respondent determined that petitioners are subject to an               
          addition to tax for negligence under section 6653 for the years             
          in issue.                                                                   
               Section 6653(a)(1) (for 1984, 1985, and 1988) or section               
          6653(a)(1)(A) (for 1986 and 1987) imposes an addition to tax                
          equal to 5 percent of the underpayment if any part of the                   
          deficiency was due to negligence or intentional disregard of                
          rules or regulations.  Section 6653(a)(2) (for 1984 and 1985) or            
          section 6653(a)(1)(B) (for 1986 and 1987) provides for an                   
          addition to tax in the amount of 50 percent of the interest                 





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