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involved the use of trustees, and petitioner agreed that those
particular transactions were taxable. Petitioner did not inform
the revenue agent that proceeds from his real estate transactions
were deposited into Mr. Miles’s law firm’s trust account, nor did
he inform him of his belief that those proceeds were not subject
to taxation if not disbursed. On April 27, 1988, this Court
entered a decision pursuant to a stipulation of the parties and
found the following deficiencies and additions to tax:
Additions to Tax
Tax Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a) 6653(a)(1) 6653(a)(2) 6661
1977 $1,082 $2,240 $54 n/a n/a n/a
1978 22,213 10,661 1,161 n/a n/a n/a
1979 63,533 15,883 3,177 n/a n/a n/a
1981 7,110 1,778 n/a $356 50% interest
on $7,110 n/a
1982 37,921 3,792 n/a 1,896 50% interest
on $37,921 $9,480
Petitioner did not file timely his Forms 1040 for 1983 and
1984. Those tax returns were filed on January 30, 1986, and
March 7, 1986, respectively. Respondent examined those tax
returns. Petitioner told the revenue agent assigned to that
examination that he was not involved in any corporations,
partnerships, or trusts. Petitioner’s income for 1983 and 1984
was determined on the basis of deposits and disbursements from
his bank accounts. The revenue agent explained to petitioner
that simply analyzing deposits into his bank account was not the
proper way to report income and did not reflect the true
financial picture of his real estate transactions. Petitioner
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