Skirvin G. Johnson - Page 2




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                                   Additions to Tax and Penalties                     
                                    Sec.     Sec.     Sec.     Sec.                   
                 Year  Deficiency 6651(f)  6653(b)(1)6663(a) 6661(a)                  
                 1988   $57,695      --     $43,271    --    $14,424                  
                 1989   50,454       --       --     $37,841   --                     
                 1990  19,458 $12,051 -- -- --                                        
               Respondent conceded that there was neither a deficiency in             
          income tax nor additions to tax due from petitioner for 1988.               
          After concessions for 1989 and 1990, the issues remaining for               
          decision are:  (1) Whether petitioner's gross income for 1989               
          includes a $94,343.16 payment to Johnson McGee Companies, NA,               
          Inc. (Johnson McGee), and $698.23 in interest earned by                     
          petitioner; (2) if so, whether the underpayment of tax                      
          attributable to those amounts is attributable to fraud; and                 
          (3) whether petitioner's gross income for 1990 includes $26,115             
          in wages.                                                                   
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue.  All            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the facts set              
          forth in the stipulation are incorporated in our findings by this           
          reference.  Skirvin G. Johnson (petitioner) resided in Phoenix,             
          Arizona, at the time the petition in this case was filed.  He has           
          a bachelor of business administration degree in marketing and               




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