Joseph Alan Piole - Page 2




                                        - 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