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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).
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Last modified: May 25, 2011