- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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