- 4 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011