- 2 -
adopts the opinion of the Special Trial Judge, as set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
DINAN, Special Trial Judge: For the taxable years 1989 and
1990, respondent determined deficiencies in petitioner’s Federal
income taxes of $37,806 and $2,579, section 6651(a)(1) additions
to tax of $9,452 and $516, and section 6654(a) additions to tax
of $2,557 and $170.
The issues for decision are: (1) Whether petitioner
received unreported income from cocaine sales in the amounts
determined by respondent and, if so, whether this income is
subject to Federal income taxation, and (2) whether petitioner is
liable for the additions to tax for failure to file timely
returns and for failure to make estimated income tax payments.
Background
Some of the facts have been deemed stipulated pursuant to
Rule 91(f) and are so found. These stipulations of fact and the
attached exhibits are incorporated herein by this reference. On
the date the petition was filed in this case petitioner resided
in the Federal Correctional Institution at El Reno, Oklahoma.
During the years in issue, petitioner resided in Ardmore,
Oklahoma and was married to Sherry L. Williams. Petitioner filed
1(...continued)
Rule references are to the Tax Court Rules of Practice and
Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011