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Addition to tax Addition to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1996 $492,138 $123,035 $26,194
1998 941 235 -0-
1999 78,215 19,554 3,785
Petitioner did not file Federal income tax returns for 1996,
1998, and 1999. As a result, respondent determined the 1996,
1998, and 1999 income tax deficiencies from information reported
to him by third parties. Based on records petitioner submitted
after the notices of deficiency were issued, respondent
recomputed the deficiencies and additions to tax as follows:
Addition to tax Addition to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1996 $220,934 $55,234 $11,759
1998 -0- -0- -0-
1999 4,839 1,210 232
After additional concessions,2 the issues for decision are:
(1) Whether petitioner had capital gain from the sale of
real property in the taxable years 1996 and 1999 and, if so, the
amount of that gain;
1(...continued)
all Rule references are to the Tax Court Rules of Practice and
Procedure. All monetary amounts have been rounded to the nearest
dollar.
2Petitioner concedes that in 1996 he received $71 of
interest income and $117 of capital gain from the sale or
exchange of stock.
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