Sheila D. Clinkscale & Jantz S. Clinkscale - Page 5

                                        - 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