Brown v. Commissioner
United States Tax Court
On his 1982 return, petitioner, a member of a professional musical group, claimed a net loss for his alleged tour promotion business activities. Respondent disallowed that net loss and determined that petitioner had a deficiency for taxable year 1982 in the amount of $ 89,423, together with additions to tax under sec. 6653(a)(1) and (2) and 6661, I.R.C. Petitioner conceded that he was liable for the deficiency, but did not concede liability for additions to tax.
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On his 1982 return, petitioner, a member of a professional musical group, claimed a net loss for his alleged tour promotion business activities. Respondent disallowed that net loss and determined that petitioner had a deficiency for taxable year 1982 in the amount of $ 89,423, together with additions to tax under sec. 6653(a)(1) and (2) and 6661, I.R.C. Petitioner conceded that he was liable for the deficiency, but did not concede liability for additions to tax. Held: Petitioner is liable for additions to tax under secs. 6653(a)(1) and (2) and 6661.
1Opinion of the Court
GEORGE M. BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brown v. Commissioner
Docket No. 17023-89
United States Tax Court
T.C. Memo 1992-15; 1992 Tax Ct. Memo LEXIS 20; 63 T.C.M. (CCH) 1750; T.C.M. (RIA) 92015;
January 8, 1992, Filed
Decision will be entered for respondent.
On his 1982 return, petitioner, a member of a professional musical group, claimed a net loss for his alleged tour promotion business activities. Respondent disallowed that net loss and determined that petitioner had a deficiency for taxable year 1982 in the amount of $ 89,423, together with additions to tax…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
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