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income and is liable for the sections 6654(a)1 and 6651(a)(1) or
(f) additions to tax.
FINDINGS OF FACT
In 1980, petitioner began operating a helicopter repair and
maintenance company. While operating the business out of his
home, petitioner provided repair and maintenance services and
equipment sales to his customers. He did not maintain a formal
set of books and records, but he did issue invoices. Petitioner
received both checks and cash for the services he provided.
Petitioner deposited most of the business proceeds into personal
and business bank accounts, and both personal and business
expenses were paid with these funds.
Petitioner’s business gross receipts in 1995, 1996, 1997,
1998, 1999, 2000, and 2001 totaled $70,899, $73,092, $149,366,
$152,353, $74,697, $67,661, and $69,691, respectively. In 1995
and 1996, petitioner received rental income from Tulsa
Helicopters, Inc., in the amounts of $33,815 and $7,363,
respectively. On June 20, 1996, petitioner sold real property
and received $400,000 in proceeds. Prior to the years in issue,
petitioner filed Federal individual income tax returns (returns)
with respondent.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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