John Robert Forrest - Page 2

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               Respondent determined deficiencies in petitioner's Federal             
          income taxes and additions to tax for the years as follows:                 
                                             Additions to Tax                         
               Year      Deficiency     Sec. 6651(a)(1)      Sec. 6654                
               1991      $850                $212.50        ---                       
               1992      832                 208.00         $36.27                    
               1993      872                 218.00         36.54                     
               1994      883                 220.75         45.85                     
               The issues for decision are:  (1) Whether petitioner                   
          received and failed to report income during the taxable years in            
          issue; (2) whether petitioner is liable for the section                     
          6651(a)(1) additions to tax for failure to file his returns for             
          the taxable years in issue; (3) whether petitioner is liable for            
          the section 6654(a) additions to tax for failure to make                    
          estimated income tax payments for 1992, 1993, and 1994; and (4)             
          whether we should impose a penalty on petitioner pursuant to                
          section 6673(a).                                                            
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Grimstead,                 
          Virginia, on the date the petition was filed in this case.                  
               Petitioner did not file Federal income tax returns for the             
          taxable years in issue.  He was a 50-percent partner in Forrest             
          Seafood Company (FSC) during the taxable years in issue.  He                
          received guaranteed payments from FSC which he has stipulated               

          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     




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