- 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.
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Last modified: May 25, 2011