Greg Olson - Page 1

                                 T.C. Memo. 2004-234                                  


                               UNITED STATES TAX COURT                                


                              GREG OLSON, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 21529-03.            Filed October 13, 2004.                

                    Respondent determined deficiencies and additions                  
               to tax for petitioner’s 1999 and 2000 taxable years.                   
                    Held:  Petitioner received taxable income during                  
               1999 and 2000, and a portion thereof is subject to                     
               self-employment tax.  Sec. 861, I.R.C., and regulations                
               thereunder, do not exempt his compensation from tax.                   
                    Held, further, petitioner is liable for the sec.                  
               6651(a)(1), I.R.C., addition to tax for failure timely                 
               to file income tax returns for each of the years in                    
               issue.                                                                 
                    Held, further, petitioner is liable for the sec.                  
               6654, I.R.C., addition to tax for failure to pay                       
               estimated tax for the year 2000.                                       

               Greg Olson, pro se.                                                    
               Cameron M. McKesson, for respondent.                                   





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