Albert Dudley Thrower - Page 2

                                        - 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