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sold poppers, we would not be able to conclude how much of the
unreported income was attributable to these sales.
D. Petitioner's Unreported Income
Petitioner admitted in his plea agreement and we find that
he had unreported income of $59,411 in 1980. As for 1981 and
1982, based upon the above findings, we conclude that petitioner
had the following unreported income:
1981 1982
Cash on hand at beginning
of year $0 $0
Add: cash sources 40,164 57,981
Cash available for year $40,164 $57,981
Less: cash uses (97,055) (101,838)
Unreported income $56,891 $43,857
II. Addition to Tax for Fraud
For 1980 and 1981, section 6653(b), and for 1982, section
6653(b)(1) provide for an addition to tax of 50 percent of the
underpayment if any part of the underpayment of tax required to
be shown on a return is due to fraud. Additionally, for 1982,
section 6653(b)(2) provides for an addition to tax equal to 50
percent of the interest payable under section 6601 with respect
to the portion of the underpayment attributable to fraud. In
this case, respondent alleges that the entire underpayments are
due to fraud.
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