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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.
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Last modified: May 25, 2011