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The issues for decision are: (1) Whether petitioner, a
resident of Hawaii and descendant of indigenous Hawaiians, is
subject to Federal income tax on income derived from sources
within the United States; (2) whether $105,000 received by
petitioner in 1989 from an uninsured motorist claim constitutes
taxable income to petitioner or is excluded under section 104(a);
(3) whether petitioner is liable for additions to tax for fraud
in the years 1986 through 1988 and fraudulent failure to file for
1989, and if not, whether petitioner is liable for alternative
additions to tax; and (4) whether petitioner is liable for
additions to tax for failure to make estimated tax payments for
the years 1987 through 1995.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Pearl
City, Oahu, Hawaii. Petitioner was born on March 20, 1944, in
Hawaii. Petitioner graduated from high school in 1962. From
1965 until 1992, petitioner was employed as a police officer by
the Honolulu Police Department. When he retired in 1992, he held
the rank of sergeant. Petitioner resided in the United States,
and all his income was derived from sources within the United
States during the years in issue. During the years 1986 through
1989, petitioner received the following amounts of income from
the described sources:
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