Gregory H. and Elizabeth A. Price - Page 2




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                                                  Accuracy-Related     Fraud          
                                   Addition to Tax       Penalty         Penalty      
          Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)     Sec. 6663     
          1989      $46,994        $6,689              --            $35,246          
          1990      32,846         1,494            --             24,635             
          1991      34,974         8,834           $6,995             --              
                                                                                     
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  All references to petitioner in the singular are to             
          Gregory H. Price.                                                           
               After concession of some issues, the primary issues for                
          decision are the amount of income that should be charged to                 
          petitioner with respect to bank deposits, whether funds received            
          from landlords for improvements to leased property constitute               
          taxable income, and whether petitioner is liable for fraud                  
          penalties, additions to tax for late filing of income tax                   
          returns, and accuracy-related penalty.                                      
               For convenience, with respect to each of respondent’s                  
          contested adjustments to petitioners’ income and expenses, we               
          combine our findings of fact and opinion.                                   

                            FINDINGS OF FACT AND OPINION                              
               Some of the facts have been stipulated and are so found.               
               When the petition was filed, petitioners resided in                    
          Glendale, Arizona.                                                          






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