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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.
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