- 3 -
Steven M. Roth, Mark A. Weiner, and Leslie B. Van Der Wal,
for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined the following
deficiencies in and penalties on petitioner’s Federal income tax:
Penalty
Year Deficiency Sec. 6662
1996 $407,880 $81,567
1997 407,880 81,567
1998 407,880 81,567
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.
The issues for decision are: (1) Which party bears the
burden of proof; (2) whether four $1 million payments petitioner
received from United Talent Agency, Inc. (UTA), in May 1996,
November 1996, May 1997, and November 1998 are excludable from
petitioner’s gross income pursuant to section 104(a)(2); and (3)
whether petitioner is liable for the accuracy-related penalty for
1996, 1997, and 1998.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011