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Federal income tax (tax):
Accuracy-Related
Year Deficiency Additions to Tax Penalty
1994 $25,531 $6,243.25 --
1995 38,555 -- $7,711
1996 89,571 22,304.75 --
The issues remaining for decision are:2
(1) Does petitioner have certain unreported income for each
of the years 1995 and 1996? We hold that he does.
(2) Is petitioner liable for 1996 for an addition to tax
under section 6651(a)(1)? We hold that he is.
FINDINGS OF FACT
Most of the facts have been deemed established pursuant to
Rule 90(c) and pursuant to the Court’s Order under Rule 91(f)
dated February 11, 2003.
At the time he filed the petition in this case, petitioner
resided in Minnetonka, Minnesota.
During each of the years at issue, Uptime Nutrition, Inc.
(Uptime Nutrition), employed petitioner.
On September 1, 1994, petitioner opened a checking account
(petitioner’s checking account) in the name of Norwest Realty,
Inc., of Minnetonka (Norwest Realty) at First Bank in Edina,
2In addition to the issues remaining for decision listed
below, there are other questions relating to certain determina-
tions in the notice of deficiency (notice) that are computational
in that their resolution flows automatically from our resolution
of the remaining issues that we address herein and from the
concessions of the parties.
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