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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.
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