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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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