Linda A. Fields - Page 7




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          $14,881 of additional interest income.  Of the $14,881 of                   
          additional interest income, the Fieldses reported that $13,881              
          derived from BIC’s commercial checking account.  The Fieldses               
          paid the resulting additional tax of approximately $500,000                 
          (approximately $150,000 for 1991 and $350,000 for 1992) with the            
          amended returns, apparently deriving approximately $450,000 of              
          such amount from refunds of erroneous FFI estimated tax payments,           
          including FFI’s $300,000 1992 estimated tax payment.                        
          Conclusion of Respondent’s Examination                                      
               In February 1997, the revenue agent notified the Fieldses              
          that, for 1991, 1992, and 1993, she proposed (1) a reduction of             
          business expense deductions for all 3 years, (2) the fraud                  
          penalty for 1991 and 1992, and (3) certain other penalties.  The            
          case then went to respondent’s Appeals Office.  As part of a                
          written settlement offer dated June 2, 1999, respondent’s Appeals           
          officer offered to concede 25 percent of the fraud penalty.  The            
          Appeals officer characterized such proposed concession as a                 
          50-percent concession of petitioner’s 50-percent share of the               
          penalty.  The Fieldses rejected that offer.                                 
               By notice of deficiency dated July 29, 1999, respondent                
          determined deficiencies, additions to tax, and penalties with               
          respect to the Fieldses’ income taxes for 1991, 1992, and 1993 as           
          follows:                                                                    








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