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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).
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