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Fantasy Sports 25% D... Fantasy Payment 16,250
Fantasy 50% payment Fantasy Payment 32,500
Fantasy Fee Final/VSS Fantasy Payment 20,170
68,920
On the 1997 Schedule C, petitioners reported gross receipts of
$60,245, total expenses of $83,481, and a loss of $23,236.
Respondent determined in the notice of deficiency dated July
12, 2001,2 that petitioners failed to report income of $27,330.
Respondent determined petitioners’ unreported income by an
examination of petitioners’ records, including the business bank
account of OTFP. The unreported income was determined as
follows:
Deposits $87,765
Less returned checks 190
Net deposits 87,575
Gross receipts reported 60,245
Unreported income 27,330
Respondent also determined that petitioners are liable for an
addition to tax under section 6651(a)(1) because the 1997 return
was not timely filed. Further, respondent determined that
petitioners are liable for an accuracy-related penalty under
2 Petitioners have not argued that the period of
limitations for assessment under sec. 6501(a) expired though
respondent issued the notice of deficiency more than 3 years
after petitioners filed the 1997 return. The 1997 return was
filed May 14, 1998, and the notice of deficiency was issued on
July 12, 2001. In any event, since we conclude that petitioners
omitted from gross income an amount properly includable therein
which is greater than 25 percent of the amount of gross income
reported in the return, the 6-year period of limitations for
assessment is applicable. Sec. 6501(e)(1)(A).
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Last modified: May 25, 2011