Steven J. and Terry L. Namyst - Page 19

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          also sold $245 worth of tools in 1997. Therefore, in total, we              
          allocate $4,014.25 for the sale of tools to petitioners’ 1997 tax           
          year.  Petitioner’s inventory list indicates that petitioner                
          transferred $320 worth of tools in 1998; therefore, $320                    
          attributable to the sale of the tools will be allocated to                  
          petitioners’ 1998 gross income.  Petitioner sold $214 worth of              
          tools in 1999; therefore, $214 attributable to the sale of the              
          tools will be allocated to petitioners’ 1999 gross income.                  
          IV. Summary of Unreported Income                                            
               In summary, petitioners improperly failed to report the                
          following amounts in their income:                                          
               Year           Sale of tools       Compensation                        
               1996           $19,371.25               -0-                            
               1997           4,014.25            $15,635.75                          
               1998           320.00              21,280.00                           
               1999           214.00              29,286.00                           
          V.  Period of Limitations for 1998                                          
               Generally, the Commissioner must assess an income tax                  
          deficiency for a specified year within 3 years from the date the            
          taxpayer's return for that year was filed.  Sec. 6501(a).                   
          However, in cases where a filed return omits from gross income an           
          amount exceeding 25 percent of the amount stated as gross income            
          on the return, section 6501(e) provides that the tax may be                 
          assessed at any time within 6 years of the filing of the return.            
          Petitioners argue that the 3-year period of limitations on                  







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