Steven W. Pond - Page 2

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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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