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