- 2 -
2. Held, further, P’s alternative contention, that the
$100,000 was excludable from income because it was a gift
from Parker, is rejected.
Craig D. Bell, for petitioner.
Dustin M. Starbuck, for respondent.
MEMORANDUM OPINION
CHABOT, Judge: Respondent determined deficiencies in
individual income tax and penalties under section 66621
(accuracy-related) against petitioner as follows:
Penalties
Year Deficiency Sec. 6662
1995 $118,980 $23,796.00
1996 746,843 149,368.60
1 Unless indicated otherwise, all section references are to
sections of the Internal Revenue Code of 1986 as in effect for
the years in issue.
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