George G. Green - Page 2

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          $25,748.40, $15,827, $10,516, and $373,688.60 for the years in              
          issue, respectively.  Additionally, respondent determined an                
          addition to tax under section 6651(a) of $93,422.15 for failure             
          to file timely for 1999.  At the time of trial, respondent                  
          asserted that the correct deficiencies were in the amounts of               
          $1,518,890, $119,466, $78,839, $113,255, and $1,865,426 for 1995,           
          1996, 1997, 1998, and 1999, respectively, with accuracy-related             
          penalties under section 6662(a) of $303,778, $23,893, $15,768,              
          $22,651, and $373,085 for the years in issue, respectively.  The            
          correct addition to tax under section 6651(a) for failure to file           
          timely in 1999 was recomputed as $93,271.                                   
               After concessions by the parties, the issues for decision              
          are:                                                                        
               (1) Whether petitioner, a cash basis taxpayer, must report             
          the damages received under a release and settlement agreement               
          into which he entered with the State of Texas, and, if so, what             
          amounts must be reported as taxable income;                                 
               (2) whether deductions that petitioner substantiated are               
          allowable under section 162 or 212;                                         
               (3) whether respondent may amend the answer to include                 
          petitioner’s attorney’s fees in his reportable gross income;                
               (4) whether petitioner is liable for section 6662(a)                   
          accuracy-related penalties for each of the years in issue; and              







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