J. McLean and Judy A. Durfey - Page 6

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         deficiency in examining respondent’s actions.  Greenberg’s                   
         Express, Inc. v. Commissioner, 62 T.C. 324, 327-328 (1974).                  
              It is clear that petitioner, an intelligent person, knew he             
         had omitted income when he filed his Federal income tax return               
         for 2002.  When asked by the Court if he had received the                    
         additional income respondent determined in the notice of                     
         deficiency, petitioner answered: “Yes, I did.  I received all                
         that”.                                                                       
              Accordingly, on the basis of the record in this case, we                
         sustain respondent’s determinations in all respects.  We hold                
         that petitioners are liable for the entire amount of the Federal             
         income tax deficiency for 2002.                                              


                                                 Decision will be entered             
                                            for respondent.                           




















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