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Compensation you received from the Federal
Bureau of Investigation for services rendered
in [sic] includible in income. Accordingly,
your taxable income for 1993 is increased
$100,000.
OPINION
Petitioner asks the Court to redetermine two of the
adjustments made in the subject notice of deficiency, the
disallowance of gambling losses in 1991 in the amount of
$19,690, and the inclusion in gross income of the lump-sum
payment of $100,000 from the FBI in 1993. Petitioner also
seeks redetermination of the accuracy-related penalty under
section 6662(a) for tax year 1991 in the amount of $475,
and of the addition to tax under section 6651(a)(1) in the
amount of $6,164 for failure to timely file his return for
tax year 1993.
At trial, petitioner presented no evidence regarding
the addition to tax under section 6654 for failure to pay
estimated tax with respect to his 1993 tax, and he made no
reference to it in his posttrial brief. Therefore, we
consider this issue waived or abandoned. See Bradley v.
Commissioner, 100 T.C. 367, 370 (1993) ("Petitioner has not
pursued this line of objection on brief, and we consider it
abandoned."). We hereby sustain respondent's determination
with respect to the addition to tax under section 6654 for
1993.
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