- 2 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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