- 2 - Unless otherwise indicated, section references are to sections of the Internal Revenue Code, as amended, and Rule references are to the Tax Court Rules of Practice and Procedure. After conceding certain items, respondent determined that petitioner is liable for deficiencies in income tax, an addition to tax, and penalties for the years and in the amounts as follows: Addition to Tax Penalty Year Deficiency Sec. 6653(b)(1) Sec. 6663 1988 $30,660 $22,995 -- 1989 33,549 -- $25,162 1990 9,280 -- 6,960 1991 37,835 -- 28,376 The issues to be decided are: (1) Whether petitioner had unreported income for the taxable years in issue as determined by respondent; and (2) whether petitioner is liable for the addition to tax and penalties for fraud.1 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. In addition, petitioner 1 Respondent conceded certain items underlying his reconstruction of petitioner=s taxable income for 1989 and 1991, resulting in a reduction of the deficiencies and fraud penalties as set forth in the notice of deficiency for those years. Because we are unable to discern the specific items that respondent has conceded, the Court=s decision in this case will be entered pursuant to Rule 155 consistent with the Court=s findings in this opinion.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011