Christa Karin Mueller - Page 2




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                         Christa Karin Mueller, pro se.                                                                                       
                         Julius Gonzalez, for respondent.                                                                                     

                                      MEMORANDUM FINDINGS OF FACT AND OPINION                                                                 

                         HALPERN, Judge: By notice of deficiency dated December 5,                                                            
                1994 (the notice), respondent determined deficiencies in, and                                                                 
                additions to, petitioner and petitioner’s husband’s 1986 Federal                                                              
                income tax liability as follows:                                                                                              
                With Respect to Husband:                                                                                                      
                                                         Additions to Tax                                                                     
                Year  Deficiency Sec. 6653(b)(1)(A)  Sec. 6653(b)(1)(B) Sec. 6661                                                             
                1986  $1,367,888                  $1,023,699                                 1              $341,233                          
                150 percent of the interest payable under sec. 6601.                                                                          
                With Respect to Petitioner:                                                                                                   
                                                                           Addition to Tax                                                    
                                 Year             Deficiency               Sec. 6661                                                          
                                 1986             $1,367,888               $341,233                                                           
                         Petitioner and her husband, Reinhard Mueller (sometimes,                                                             
                husband), made a joint return of income for 1986 (the 1986                                                                    
                return).  The principal adjustments giving rise to respondent’s                                                               
                determination of a deficiency in tax are respondent’s positive                                                                
                adjustment to gross income on account of three items determined                                                               
                by respondent to have been omitted from gross income:                                                                         
                (1) embezzlement income of husband in the amount of $485,177,                                                                 
                (2) stock-related gain of husband in the amount of $2,299,920,                                                                
                and (3) stock-related gain of husband in the amount of $5,068.                                                                






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