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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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