- 2 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011