- 3 - Alleged Business Loans to UVW ............ 88 Alleged Reimbursements ................ 100 Alleged Advances To Purchase Personal Items ..... 101 Alleged Rental Payments ............... 104 Alleged Items of MZ Trading ............. 105 Alleged Repayments of Loans ............. 117 Claimed Cost of Goods Sold ................ 119 Claimed Schedule C Deductions ............... 122 Claimed Interest Deductions ............. 125 Claimed Telephone Expense Deductions ......... 127 Claimed Bad Debt Deduction .............. 132 Claimed Capital Loss: Church Street Property ....... 134 Claimed Capital Gain: Sanchez Street Property ...... 138 Claimed Schedule E Deductions ............... 142 Fraud Penalty Under Section 6663(a) ............ 149 Underpayment ..................... 149 Fraudulent Intent .................. 150 Accuracy-Related Penalty Under Section 6662(a) ...... 153 Addition to Tax Under Section 6651(a)(1) ......... 156 CHIECHI, Judge: Respondent determined the following defi- ciencies in, addition under section 6651(a)(1)1 to, and fraud penalties under section 6663(a) on petitioner’s2 Federal income 1All section references are to the Internal Revenue Code (Code) in effect for the years at issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. 2Respondent issued to both petitioner and his former wife, Natalya Brodsky (Ms. Brodsky), a notice of deficiency (notice) for 1991 and 1992 and a separate notice for 1993. Ms. Brodsky did not join in the petition that petitioner filed and is not a party in the present case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011