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Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1989 $2,214 $554
1990 2,189 547
1991 3,088 772
1992 4,109 1,027
1993 1,470 368
1994 471 118
In the notice of deficiency, respondent determined that
petitioner had failed to file Federal income tax returns for all
subject years. Respondent further determined for the years 1989
through 1992 that petitioner earned Schedule C income in the
respective amounts of $10,637, $10,637, $13,970, and $17,797.
These determinations were based upon Bureau of Labor statistics
for one person living in rented premises in the Fresno,
California, area, and were adjusted downward, in some years, to
account for nontaxable worker’s compensation that petitioner had
received.
For the taxable years 1993 and 1994, respondent determined
that petitioner earned interest income of $8,862 and $10,
respectively, and Schedule C income of $3,750 and $4,050,
respectively. For 1994, respondent further determined that
petitioner had nonemployee compensation of $2,959.
For each of the years 1989 through 1994, respondent
determined that petitioner was liable for self-employment tax,
and, for the years 1990 through 1994, that petitioner was
entitled to a deduction for one-half of the self-employment tax
determined. Finally, respondent determined that petitioner was
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Last modified: May 25, 2011