- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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