- 5 - Clinkscale in which respondent determined that Mr. Clinkscale and Ms. Clinkscale underreported adjusted gross income for the taxable years 1994, 1995, 1996, and 1997 by $83,822, $101,633, $250,335, and $325,199, respectively,4 and that they have defi- ciencies in tax for those years of $19,927, $25,238, $71,385, and $107,698, respectively. Respondent also determined in the notice that Mr. Clinkscale and Ms. Clinkscale are liable for the taxable years 1994, 1995, 1996, and 1997 for fraud penalties under section 6663(a) of $14,945.25, $18,928.50, $53,538.75, and $80,773.50, respectively. The petition filed in this case alleged: 1. Petitioner(s) disagree(s) with the tax defi- ciency(ies) for the year(s) 1994, 95, 96 as set forth in the NOTICE OF DEFICIENCY dated April 12, 2001 * * * * * * * * * * 3. Petitioner(s) dispute(s) the following: Amount of Defi- Addition to Tax ciency (Penalty) if any, Year Disputed Disputed 1994 All total All total 1995 All total All total 1996 All total All total 4. * * * As set forth in plea agreement, all taxes from 1994, 95 96 have been dismissed only 1997 is in question. Appeals are in concerning 1997 and await- 4Respondent utilized the bank deposits method in order to reconstruct Mr. Clinkscale and Ms. Clinkscale’s adjusted gross income for each of the taxable years 1994, 1995, 1996, and 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011