- 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
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