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GOPAL v. COMMISSIONER

Docket No. 21531-82.

55 T.C.M. 1694 (1988)

T.C. Memo. 1988-394

Peter K. Gopal v. Commissioner.

United States Tax Court.

Filed August 23, 1988.

Attorney(s) appearing for the Case

Harry J. Kaplan, 111 West St. John St., San Jose, Calif., for the petitioner. Steven A. Wilson, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Chief Judge:

Respondent determined a deficiency in petitioner's 1978 Federal income tax in the amount of $309,974.14 and an addition to tax for fraud under section 6653(b)1 in the amount of $154,987.07.

The issues for decision are:

1) Whether deposits of $352,914.40 to petitioner's bank accounts and $125,990.00 of partnership capital contributions represented unreported...

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