- 2 - Additions to Tax Sec. Sec. Sec. Deficiency 6651(a)(1) 6653(a)(1) 6654(a) $1,020,626 $255,156.50 $51,031 $65,550 The issues for decision are: (1) The amount, if any, of petitioner’s 1988 unreported rental income; (2) whether petitioner had $3,400,351 of unreported income from illegal activities in 1988, as respondent determined; and (3) whether petitioner is liable for additions to tax.2 FINDINGS OF FACT When he petitioned this Court, petitioner was incarcerated at Allen Correctional Institute in Lima, Ohio. During 1988, petitioner owned at least 141 rental properties in Akron, Ohio. Conducting business under the name of “College Rentals”, 545 Grant Street, Akron, Ohio, he rented these properties mainly to college students. In August 1988, the Akron, Ohio, Police Department arrested petitioner on charges of trafficking in marijuana. The arrest occurred in the apartment of one of petitioner’s associates at 80 S. Portage Path, Akron, Ohio. 2 On brief, petitioner has advanced various meritless arguments. For example, petitioner contends that the limitations period for assessing his 1988 tax liability has expired. Petitioner, however, failed to file a 1988 tax return; therefore, “the tax may be assessed * * * at any time.” Sec. 6501(c)(3).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011