- 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