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Table 1
Item Amount
Unreported income1 $25,377.81
Sched. C adjustments--net 195,715.95
Sched. A adjustment--
consequential2 6,389.00
Sched. A adjustments--other (658.59)
Deficiency 83,632.30
Addition--sec. 6653(a)(1)(A) 4,181.62
Addition--sec. 6653(a)(1)(B) 3
Addition--sec. 6661 20,908.08
1 All of the unreported income was from Edward’s law practice.
2 Reduction in medical expense deduction, resulting from increase
in adjusted gross income because of additional income from
Edward’s law practice.
3 Fifty percent of the interest on $83,632.30.
Petitioners agreed to these proposed changes, and the
appropriate amounts were assessed.
Respondent seized certain of petitioners’ property in 1994,
sold the property in 1995, and in 1995 applied $69,617 of the
proceeds to petitioners’ interest on the underpayment of their
1987 tax liability.
The $69,617 interest payment was not related to any
liability on petitioners’ 1987 tax return as originally filed, as
all such liability had been timely paid. This interest payment
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Last modified: May 25, 2011