Juan Rodriguez - Page 2




                                          - 2 -                                       
                                 Penalty and Addition to Tax                          
             Year   Deficiency   Sec. 6651(a)  Sec. 6554 Sec. 6662(a)                 
             1990     $2,284         $571       $150      -0-                         
             1991      2,374          -0-       –0-       $475                        
             1993     24,654     6,164          1,035     –0-                         

                  After concessions, the issues for decision are:  (1)                
             Whether petitioner is entitled to deduct wagering losses                 
             in the amount of $19,690 for the taxable year 1991; (2)                  
             whether petitioner must include in gross income a payment                
             in the amount of $100,000 that he received during 1993                   
             from the Federal Bureau of Investigation (FBI) and, if so,               
             whether he is entitled to deduct a portion of such amount                
             as relocation expenses; (3) whether petitioner is liable                 
             for the accuracy-related penalty under section 6662(a) for               
             the taxable year 1991; (4) whether petitioner is liable                  
             for the addition to tax under section 6651(a)(1) for                     
             failure to file a timely return for 1993; and (5) whether                
             petitioner is liable for the addition to tax under section               
             6654 for failure to pay estimated income tax for the                     
             taxable year 1993.  Unless stated otherwise, all section                 
             references in this opinion are to the Internal Revenue                   
             Code as in effect during the years in issue.                             

                                  FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are so                   
             found.  The stipulation of facts and the attached exhibits               





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