- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011