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his interest in the residence of petitioner and Mr. Monsour.
In 1991, Mr. Monsour transferred to petitioner one-half of
his interest in the Open Heart property.
In 1997, Mr. Monsour transferred to petitioner one-half of
his interest in 30 acres of land, which at all relevant times he
and one of his brothers (Howard Monsour) owned and which was
located behind Monsour Medical Center, a hospital that Mr.
Monsour had owned and operated at all relevant times since 1964.
In 1997, Mr. Monsour transferred to petitioner one-half of
his interest in Laurel Valley Farms.
At a time not disclosed by the record, petitioner and Mr.
Monsour jointly filed Form 1040, U.S. Individual Income Tax
Return (Form 1040), for each of their taxable years 1987 and
1988.
On March 19, 1993, respondent issued to petitioner and Mr.
Monsour a notice of deficiency (notice) with respect to their
taxable years 1987 and 1988 (notice for the taxable years 1987
and 1988). In that notice, respondent determined the following
deficiencies in, and additions to, the tax of petitioner and Mr.
Monsour:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661
1987 $15,851 -- $1,066 1 $5,332
1988 21,416 $1,627 -- -- 8,133
150% of the interest due on the deficiency.
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