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In each of the years in issue, petitioner was married to
Flor Shea. Petitioner and Mrs. Shea were divorced in 1993.
Petitioner filed timely joint returns with Mrs. Shea in 1990 and
1991. Petitioner's 1992 return was filed on March 31, 1995, as a
joint return. In the notice of deficiency for 1992, respondent
determined that petitioner's correct filing status was married
filing separately. The notice also contains various
consequential adjustments. The parties now agree that married
filing separately is the correct 1992 filing status for
petitioner.
In each of the years in issue, petitioner was the owner and
operator of an unincorporated consulting business known as Shea
Technology Group, hereafter referred to as STG. Petitioner
reported income and deductions from this business on Schedule C,
Profit or Loss From Business, in each of the years in issue. The
parties now agree that petitioner underreported STG's gross
business receipts by $216,143 in 1990, $208,134 in 1991, and
$272,902 in 1992.3
3Respondent proposed that we find these unreported gross
receipt figures, and petitioner indicated that he did not object.
In respondent's reply brief, he states that the total amount of
unreported gross receipts for 1992 is $274,902. We will use the
lower figure to which the parties have agreed.
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