Juan Rodriguez - Page 11




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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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