- 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
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