- 4 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011