Zinovy Brodsky - Page 4




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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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