- 2 - Additions to Tax1 Sec. Sec. Sec. Year Deficiency 6653(b)(1) 6653(b)(1)(A) 6661 1985 $45,079 $22,540 $11,270 1986 62,984 $112,210 15,746 1Respondent also determined that the additions to tax under sec. 6653(b)(2) and (b)(1)(B) apply to the deficiencies. Following petitioner’s concession1 and a June 7, 1999, Oral Opinion of this Court that petitioner is collaterally estopped from contesting the applicability of the section 6653(b) additions to tax on account of his conviction for income tax evasion for the subject years, see sec. 7201, we are left to decide: 1. Whether petitioner’s income for the respective years in issue should be increased by unreported income of $217,162 and $94,439 from the false invoice scheme described below. We hold that his unreported income from that scheme was $172,019 and $49,296, respectively.2 1 Petitioner has not directed our attention to any evidence (and did not make any arguments on brief) as to respondent’s determination of the additions to tax under sec. 6661. We conclude that petitioner has conceded this issue, if, in fact, the Rule 155 computation shows that his income tax understatement is “substantial” within the meaning of sec. 6661(b)(1). See Rule 151(e)(4) and (5); see also Rule 142(a). 2 Respondent also determined that petitioner's income should be adjusted to reflect adjustments made to his distributive share of income/loss from a partnership; the adjustment stemmed from a tax-evasion scheme other than the one discussed herein. Petitioner has not contested respondent’s proposed findings of fact as to this determination, and the record clearly supports those proposed findings. We sustain respondent’s determination as to this adjustment without further discussion.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011