- 16 - 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. PetitionerPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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