Robert C. MacElvain - Page 4




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          C. Taxable Year 1982                                                        
               On June 12, 1989, respondent issued a notice of deficiency             
          to petitioner determining a deficiency in and additions to his              
          Federal income tax for 1982.  On September 5, 1989, petitioner              
          filed a timely petition with the Court (assigned docket No.                 
          21830-89) contesting the notice of deficiency for 1982.  On May             
          17, 1991, the Court entered a stipulated decision that petitioner           
          was liable for a deficiency in income tax in the amount of                  
          $36,016, an addition to tax under section 6653(a)(1) in the                 
          amount of $1,800.80, an addition to tax under section 6653(a)(2)            
          in an amount equal to 50 percent of the interest due on the                 
          deficiency, and an addition to tax under section 6661 for                   
          substantial understatement of liability in the amount of                    
          $9,004.00.                                                                  
               Petitioner did not file any notice of appeal in docket No.             
          21830-89.  Accordingly, the Court's decision in that docket has             
          long been final.  See secs. 7481(a)(1), 7483.                               
          D. Taxable year 1983                                                        
               On June 15, 1990, respondent issued a notice of deficiency             
          to petitioner determining a deficiency of $167,381 in his Federal           
          income tax for 1983.  Respondent also determined that petitioner            
          was liable for additions to tax under section 6653(b)(1) and (2)            
          for fraud and under section 6661 for substantial understatement             
          of liability.                                                               







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