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(7) Whether petitioner failed to report various items of
income on his 1992, 1993, and 1994 individual income tax returns.
We hold that he did, although in lesser amounts than determined
by respondent.
(8) Whether petitioner is liable for additions to tax and
accuracy-related penalties under sections 6651(a)(1) and 6662(a),
respectively. We hold that he is liable for both, although in
lesser amounts than determined by respondent.
Respondent’s additional adjustments to petitioner’s
exemptions, itemized deductions, self-employment taxes, and
taxable Social Security benefits are computational and will be
resolved by our holdings on the foregoing issues.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, first through third supplemental
stipulations of facts, associated exhibits, and oral stipulations
are incorporated by this reference. Petitioner resided in
Newport Beach, California, at the times he filed the petitions in
these cases, which have been consolidated for the purposes of
trial, briefing, and opinion.
Petitioner’s Business and Estate Planning Activities
Over the years, petitioner engaged in several business
activities, including cement hauling, retail gasoline sales,
residential real estate rentals, and truck and equipment rentals.
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