Steven K. Han - Page 2





                                        - 2 -                                         

                       Additions to tax                                               
          Deficiency      Sec. 6651(a)    Sec. 6653(a)(1)   Sec. 6661                 
          $31,101           $7,697           $1,766          $7,775                   
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the year in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               In an amendment to petition, petitioner alleged that the               
          income reported on his 1988 return should be reduced by $27,992             
          because he erroneously reported interest income that was earned             
          on funds that belonged to his wholly owned corporation, N.A.                
          Tours, Inc.  In an amendment to answer to amendment to petition,            
          respondent asserted that an increased deficiency for 1988 arose             
          from (1) unreported income from theft of $986,856, dividend                 
          income of $20,641, capital gains from real estate sales of                  
          $107,021, and ordinary income from those sales of $2,638; and (2)           
          a change in petitioner’s filing status from single to married               
          filing separately.  Respondent further asserted that the                    
          additions to tax determined in the notice of deficiency under               
          sections 6651(a), 6653(a)(1), and 6661 for 1988 should apply to             
          the increased deficiency.                                                   











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