Donald B. Hawksley - Page 8




                                        - 8 -                                         
          version of the 30-day letter for 1986 to petitioner by certified            
          mail at the address in Clermont, Florida.                                   
               On March 19, 1990, respondent sent a notice of deficiency to           
          petitioner at petitioner’s last known address in Clermont,                  
          Florida.  In the notice, respondent determined a deficiency in              
          petitioner’s income tax for 1986 in the amount of $47,294.  The             
          deficiency was attributable in large part to three adjustments:             
          (1) The disallowance of petitioner’s Schedule C deductions in the           
          amount of $23,791; (2) the disallowance of petitioner’s Schedule            
          E partnership losses in the amount of $47,304; and (3) unreported           
          gain from the sale of shares in United Funds, Inc. in the amount            
          of $29,958.7  In the notice, respondent also determined additions           
          to tax for negligence under section 6653(a)(1)(A) and (B) and for           
          substantial understatement of liability under section 6661.                 
               Petitioner received the notice of deficiency for 1986.                 
          However, petitioner did not file a petition with this Court                 
          contesting respondent’s deficiency determinations.  Accordingly,            
          on August 20, 1990, respondent assessed the deficiency in income            
          tax ($47,294) and the additions to tax against petitioner.                  
          C.  Mr. Amigron’s Arrest                                                    
               On May 3, 1991, Mr. Amigron was arrested in California by              
          inspectors of respondent’s Internal Security Division in                    

               7  Respondent determined the amount of gain based, in part,            
          on petitioner’s failure to demonstrate any basis in the shares.             
          See secs. 1001, 1011(a).                                                    





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