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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.
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