Michael Sponberg - Page 2




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          with respect to each of petitioner’s taxable years 1987 and 1990.           
          We hold that, except for respondent’s concession with respect to            
          petitioner’s taxable year 1987, respondent did.                             
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found with           
          one exception stated herein.                                                
               Petitioner resided in Palos Verdes Estates, California, at             
          the time he filed the petition in this case.                                
               On August 15, 1985, April 15, 1986, and October 11, 1988,              
          respectively, petitioner filed Forms 1040, U.S. Individual Income           
          Tax Return (Form 1040), for his taxable years 1984 (1984 return),           
          1985 (1985 return), and 1986 (1986 return).  As reflected in Form           
          4340, Certificate of Assessments, Payments, and Other Specified             
          Matters (Form 4340), with respect to each of petitioner’s taxable           
          years 1984 and 1985 and in respondent’s complete statement of               
          petitioner’s account with respect to his taxable year 1986                  
          (respondent’s statement of petitioner’s account with respect to             
          his taxable year 1986),1 respondent assessed on various dates the           
          following amounts of Federal income tax (tax), additions to tax,            
          and interest:                                                               



               1We attach hereto as Appendix A, Appendix B, and Appendix C,           
          respectively, and incorporate herein by this reference, the                 
          information reflected in Form 4340 with respect to each of                  
          petitioner’s taxable years 1984 and 1985 and respondent’s state-            
          ment of petitioner’s account with respect to his taxable year               
          1986.                                                                       




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