- 2 -
1991 256,233 192,175
1992 86,650 61,988
As an alternate position, respondent determined that, if the
fraud penalty does not apply, petitioner is liable for the
accuracy-related penalty under section 6662(a) for negligence or
substantial understatement of tax for each of the years in issue.
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, unless
otherwise indicated
After concessions by the parties,1 the issues to be decided
are as follows:
1. Whether petitioner failed to report gross receipts of
$344,225 for 1990, $666,563 for 1991, and $53,330 for 1992.
2. Whether petitioner is entitled to offsets and business
deductions in excess of those allowed by respondent for the 1992
taxable year.
3. Whether petitioner is entitled to an embezzlement loss
deduction for the 1990 taxable year.
4. Whether petitioner is liable for the fraud penalty under
section 6663 for the 1990, 1991, and 1992 taxable years.
1Petitioner concedes that he is not entitled (1) to the
alimony deduction he claimed on his income tax returns for the
taxable years 1990, 1991, and 1992, and (2) to business
deductions for payments of $49,685 and $45,700 made to Julie Anne
Stanbery during 1990 and 1991.
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