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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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Last modified: May 25, 2011