- 4 - tax (tax): Addition to Tax Fraud Penalty Year Deficiency Under Sec. 6651(a)(1) Under Sec. 6663(a) 1991 $60,952 --- $45,714 1992 155,798 --- 116,849 1993 397,861 $98,365 298,396 Respondent determined in the alternative to the determinations under section 6663(a) that petitioner is liable for each of the years at issue for the accuracy-related penalty under section 6662(a). The issues remaining for decision are: (1) Does petitioner have unreported income for each of the years at issue? We hold that he does to the extent stated herein. (2) Is petitioner entitled to reduce for each of the years at issue his Schedule C gross receipts by certain claimed cost of goods sold? We hold that he is not. (3) Is petitioner entitled to deduct for each of the years 1991 and 1992 certain claimed Schedule C expenses? We hold that he is not. (4) For 1992, did petitioner realize a loss from the sale of certain real property located at 1020 Church Street, San Francisco, California (Church Street property), or did he realize a gain from that sale in the amount determined by respondent? We hold that he did not realize a loss, but that he realized, and is required to recognize, the gain determined by respondent.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