Calvin L. Eubanks - Page 3




                                        - 2 -                                         
          decision to be entered is not reviewable by any other court, and            
          this opinion should not be cited as authority.                              
               On July 10, 2001, respondent issued to petitioner a Notice             
          of Determination Concerning Collection Action(s) Under Section              
          6320 and/or 6330 for unpaid 1992 Federal income tax and related             
          liabilities in the amount of $10,132.48.  The issue for decision            
          is whether petitioner is liable for the Federal income tax                  
          liability reported on his untimely 1992 Federal income tax                  
          return.  The resolution of this issue depends upon whether                  
          certain income reported on petitioner’s 1992 return is includable           
          in petitioner’s income for that year.                                       
          Background                                                                  
               Some of the facts have been stipulated and are so found.  At           
          the time the petition was filed, petitioner resided in Memphis,             
          Tennessee.                                                                  
               Petitioner was one of three incorporators of W.H.Y.                    
          Construction Company, Inc. (W.H.Y. or WHY), incorporated in                 
          Tennessee on May 12, 1989.  W.H.Y. was administratively dissolved           
          by the Secretary of State of Tennessee on February 15, 1991,                
          because the corporation failed to file a report required by                 
          Chapter 16 of the Tennessee Business Corporation Act.  While in             
          existence, W.H.Y. was involved in residential construction and              
          renovations.                                                                








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011