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Additions to Tax
Year Deficiency Sec. 6651(f)1 Sec. 6654(a)
1989 $21,867 $16,400 $1,478
1990 19,575 14,681 1,287
1991 3,873 2,905 224
1992 4,017 3,013 175
After concessions,2 the issues for decision are as follows:
(1) Whether amounts paid to or received by Real Services, Inc.,
during 1989 and 1990 are properly treated as petitioner’s taxable
income; (2) whether petitioner failed to report income received
in connection with an “escort” business during 1989 and 1990; (3)
whether petitioner failed to report income she received through
embezzlement and/or fraudulent loan transactions during 1989 and
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 In connection with the pretrial proceedings in this case,
respondent was deemed to have conceded his determinations that
petitioner had unreported income of $4,640 in 1990 as a result of
a transaction with an individual identified as Harvey K. and
unreported income of $1,500 as a result of a transaction with one
Dennis T. Additionally, on brief, respondent has conceded his
determination that petitioner had unreported income of $1,030 as
a result of a transaction with an individual identified as
Ricardo S.
The determinations in the deficiency notice included amounts
of self-employment taxes for the years in issue. Petitioner has
not specifically contested the applicability of these taxes, and
we deem that she has conceded this issue. The amount of self-
employment taxes, and the commensurate deductions for those
taxes, are to be determined in accordance with our conclusions
herein regarding petitioner’s unreported income.
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Last modified: May 25, 2011