- 2 -
In Docket No. 9302-97:
Accuracy
-related
Additions to Tax Penalties
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(b)(1) 6663 6662(a)
1988 $146,963 $10,062 $2,743 $75,364 --- ---
1989 39,772 9,943 --- --- $20,069 $2,208
1990 224,046 56,011 --- --- 91,597 20,383
In Docket No. 5434-98:
Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6653(b)(1)(A)
6653(b)(1)(B)
1987 $334,292 $11,533 $2,660 1 $210,818 2
1 50% of the interest due on the portion of the underpayment attributable
to negligence.
2 50% of the interest due on the portion of the underpayment attributable
to fraud.
After concessions,2 the issues for our consideration are:
(1) Whether petitioner’s 1987, 1988, and 1989 income tax returns
are valid returns of petitioner; (2) whether petitioner is liable
for increased deficiencies under section 6214(a)3 for his 1987,
1988, and 1989 tax years; (3) whether petitioner’s Schedule C,
Profit or Loss From Business, income was understated for the
1987, 1988, 1989, and 1990 tax years; (4) whether petitioner
2 Respondent has conceded that petitioner is entitled to the
itemized deductions claimed on Schedule A, Itemized Deductions,
of petitioner’s 1990 tax return. Respondent has also proposed to
increase the deductions for wages on petitioner’s Schedules C.
The parties have also stipulated that petitioner incurred a
capital loss of $9,844 on the sale of stock during 1990.
3 Unless otherwise indicated, all section references are to
the Internal Revenue Code for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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