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RUWE, Judge: Respondent determined deficiencies in
petitioner’s Federal income taxes and additions to tax as
follows:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B)
1985 $86,533 $43,736 50% of the --- ---
Interest Due
on $87,471
1986 165,732 --- --- $124,340 50% of the
Interest Due
on $165,787
1987 309,456 --- --- 232,092 50% of the
Interest Due
on $309,456
1988 64,910 51,021 --- --- ---
After concessions,1 the issues for decision are: (1) Whether
petitioner had unreported income from various real estate
transactions, from commissions, interest, rents, and unidentified
deposits for the years in issue; (2) whether petitioner is liable
for additions to tax for fraud under section 6653(b);2 and (3)
whether assessment of the alleged deficiencies is barred by the
statute of limitations. For convenience and clarity, general
findings of fact are discussed first followed by a statement of
general legal principles applicable to this opinion; separate
1The concessions of petitioner and respondent, as well as
the amounts which remain in dispute, are detailed in app. C.
Petitioner on brief adopts respondent’s statement of the issues
settled by the parties and the accompanying schedules thereto.
2Unless 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.
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