Thomas Lee Woodall - Page 2




                                        - 2 -                                         
               Additions to Tax          Penalty                                      
          Year   Deficiency   Sec. 6651(a)(1)   Sec. 6654   Sec. 6662                 
          1992    $117,034        $29,258                    $23,407                  
          1993     361,493         90,373        $5,447                               
          1994      48,973         12,243         2,541                               
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               After concessions,2 the issues for decision are:  (1)                  
          Whether petitioner had additional unreported income for 1992,               
          1993, and 1994, (2) whether petitioner is liable for an addition            
          to tax pursuant to section 6651(a)(1) for 1992, 1993, and 1994,             
          (3) whether petitioner is liable for an addition to tax pursuant            
          to section 6654 for 1993 and 1994, and (4) whether petitioner is            
          liable for a penalty pursuant to section 6662 for 1992.                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in New York, New York.                         


               2  Petitioner concedes that deposits totaling $168,948,                
          $133,022, and $41,124 in 1992, 1993, and 1994, respectively, are            
          taxable income to petitioner for 1992, 1993, and 1994,                      
          respectively.  Respondent concedes that deposits totaling $3,897,           
          $3,665, and $3,951 in 1992, 1993, and 1994, respectively, are not           
          taxable income to petitioner.  Additionally, respondent concedes            
          that petitioner received gifts totaling $10,000 in 1992 and                 
          $19,949 in 1993.                                                            




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