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resulting deficiencies in income tax and additions to tax are as
follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)1 Sec. 6654(a)
1982 $454,752 $113,688 $22,738 $44,274
1983 855,081 213,770 42,754 52,325
1984 960,807 240,202 48,040 60,407
1985 1,045,458 261,365 52,273 59,909
1986 787,428 196,857 39,371 38,097
1987 101,574 25,394 5,079 5,489
1988 28,064 7,016 1,403 1,794
1Respondent also determined that the time sensitive
addition to tax under section 6653(a)(2) also applied for 1982
through 1988, and that the time sensitive addition to tax under
section 6653(a)(1)(B) applied to 1986 and 1987.
We decide the following issues:
1. Whether the presumption of correctness attaches to
respondent's deficiency determination. We hold it does.
2. Whether petitioner's gross income includes receipts from
tax shelter promotion activities as determined by respondent in
the following amounts:
Year Amount
1982 $916,997
1983 1,720,483
1984 1,932,671
1985 2,101,968
1986 1,585,676
1987 266,681
1988 83,045
We hold it does.
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