- 163 - Respondent’s Amendment to Answer Citrus County Property: Respondent originally determined that petitioner realized $49,907 as forgiveness of indebtedness income in 1987. Respondent alternatively alleges that petitioner realized $112,156 of ordinary income from the sale of that property in 1985. Tai Property: Respondent alleges that petitioner realized additional income of $50,863 from the sale of real property in 1985. As a result of those allegations, respondent asserts an additional deficiency of $80,523. Thus, respondent claims a total revised income tax deficiency of $167,056 for 1985. Respondent also alleges that those items of income were omitted with fraudulent intent to evade tax and asserts an increased sec. 6653(b)(1) addition to tax of $40,402 (revised addition to tax for fraud of $84,188 for 1985), and an increased sec. 6653(b)(2) addition to tax of 50 percent of the interest due on the revised underpayment of $167,056. Total adjustments to Schedule C income: $163,019 Taxable income from notice of deficiency: $202,816 Corrected taxable income: $365,835 Tax: $163,321 Self-employment tax: $4,673 Total corrected tax liability: $167,994 Total tax shown on return or as previously adjusted: $1,320 Adjustment to earned income credit: ($382) Deficiency - increase in tax: $167,056Page: Previous 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 Next
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