Raymond E. Vogt, Jr. - Page 2




                                         -2-                                          
                                      Additions to Tax/Penalties                      
                                  Sec.       Sec.     Sec.     Sec.                  
          Year   Deficiency     6651(a)(1)    16663     6654    26651(f)              
          2000    $13,513     $3,479      $5,076     --        --                     
          2001     22,722          4,876      15,317     --        --                 
          2002      5,644          1,564       3,980     --        --                 
          2003     23,585           --          --      $617    $17,688               
               1In the alternative to fraud penalties under sec. 6663,                
          respondent determined accuracy-related penalties under sec. 6662            
          of $1,354, $4,085, and $1,061 for the years 2000, 2001, and 2002,           
          respectively.                                                               
               2In the alternative to a sec. 6651(f) addition to tax for              
          the year 2003, respondent determined an addition to tax under               
          sec. 6651(a)(1) in the amount of $5,307.                                    
               After concessions,2 the issues for decision are:  (1)                  
          Whether petitioner received unreported income for 2000, 2001,               
          2002, and 2003 (years at issue); (2) whether petitioner is                  
          entitled to certain itemized deductions for the years at issue;             
          (3) whether petitioner is entitled to a claimed Schedule E,                 
          Supplemental Income and Loss, rental expense deduction for 2001;            
          (4) whether petitioner is liable for self-employment tax under              
          section 1401 for 2001, 2002, and 2003; (5) whether petitioner is            
          liable for fraud penalties under section 6663 for 2000, 2001, and           
          2002, or alternatively, accuracy-related penalties under section            


               1(...continued)                                                        
          otherwise indicated.  Amounts are rounded to the nearest dollar.            
               2In his amendment to answer, respondent conceded income                
          adjustments related to certain partnership distributions.  On               
          brief, respondent conceded income adjustments related to                    
          Peninsula Communications of $13,376 and $48,001 for tax years               
          2000 and 2001, respectively.  In addition, respondent conceded              
          adjustments based on bank deposits into California Federal Bank             
          of $18,527 for tax year 2002.                                               





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