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was reduced from $1,064,611 to $972,864 resulting in a $91,747
refund claim.
Respondent issued the notice of deficiency in dispute on
November 29, 2004. With respect to the income tax liability for
2000, the notice of deficiency increased capital gains by
$87,735, reduced wages by $134,023, and denied $204,709 of
itemized deductions, resulting in a determined deficiency of
$183,743 together with a $36,749 section 6662 accuracy-related
penalty.
2. 2001 Federal Income Tax Return
Mr. Isaacson prepared petitioner’s 2001 Federal income tax
return with an attached Form 8275 setting out his legal position.
The return reported wages from Veritas of $70,939, capital gain
of $698,312, miscellaneous income of $6,555, and itemized
deductions of $41,625, resulting in taxable income of $734,181.
The return reported regular income tax of $148,209, no
alternative minimum tax, and a credit for the prior year’s
minimum tax of $138,957, resulting in a $9,252 tax liability.
The notice of deficiency issued on November 29, 2004, with
respect to 2001 reduced the credit for the prior year’s minimum
tax from $138,957 to $62,730, resulting in a determined
deficiency of $76,227 together with a $15,245 section 6662
accuracy-related penalty.
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