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3. Alleged Brokerage Account Losses
Petitioner contends that respondent failed to account for
margin charges and large losses that he allegedly sustained in
his Brown & Co. brokerage account in 1985, 1986, and 1987. There
is no evidence to support petitioner’s claim.
4. Conclusion Regarding Unreported Income
We sustain respondent’s determination that petitioner had
unreported income of $600,515 for 1985, $787,080 for 1986, and
$1,008,325 for 1987.
D. Failure To Pay Estimated Tax Under Section 6654
Respondent determined that petitioner is liable for the
addition to tax under section 6654 for failure to pay estimated
tax for 1987. We have jurisdiction to review this determination
because the taxpayer did not file a return for 1987. Sec.
6665(b)(2); Meyer v. Commissioner, 97 T.C. 555, 562 (1991).
Petitioner offered no evidence and made no argument on this
issue. We conclude that petitioner is liable for the addition to
tax for failure to pay estimated tax under section 6654 for 1987.
E. Whether Petitioner Is Liable for the Addition to Tax for
Substantial Understatement of Income
Petitioner contended in the petition that he is not liable
for the addition to tax for substantial understatement of income
tax under section 6661(a) for 1985 and 1986. Section 6661(a)
imposes an addition to tax of 25 percent of the amount of any
underpayment attributable to a substantial understatement of
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