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for 1987, 1988, and 1989 as follows:2
Docket No. 3275-01
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)
1987 $20,861 $15,646 50% of the interest --
due on $20,861
1988 3,213 -- -- $2,410
Docket No. 3276-01
Penalty
Year Deficiency Sec. 6663
1989 $10,494 $7,871
Docket No. 3277-01
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6653(b)
1987 $12,005 $9,004 50% of the interest --
due on $12,005
1988 9,985 -- -- $7,489
The issues remaining to be decided are:3
1. Whether decedent, Armand J. Del Bosque (Mr. Del Bosque),
had unreported gross receipts for 1987, 1988, and 1989 in the
respective amounts of $67,163, $16,557, and $32,779, computed
under the net worth method.
2All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure. Amounts are rounded
to the nearest dollar.
3The parties have stipulated that (1) Bradley T. Jacobsen
(Mr. Jacobsen) and Donna M. Cleare-Jacobsen (Mrs. Jacobsen) are
entitled to deduct in 1987 the $2,000 contribution to an IRA that
respondent disallowed, (2) Virginia Ferguson is entitled to
relief under sec. 6015(c) with respect to the deficiencies and
additions to tax for 1987 and 1988, and (3) Mrs. Jacobsen is
entitled to relief under sec. 6015(b) with respect to the
deficiencies and additions to tax for 1987 and 1988.
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