Christopher Richardson - Page 2

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               Respondent concedes that petitioner is not liable for the              
          addition to tax under section 6651(a)(2) for failure to pay for             
          the years in issue.1                                                        
               After respondent’s concession, the issues for decision are:            
               1.  Whether petitioner had unreported income as determined             
          by respondent for 1998-2001.  We hold that he did.                          
               2.  Whether petitioner is liable for self-employment tax on            
          his earnings from Eniva Corp. of $221 for 2000 and $112 for 2001.           
          We hold that he is.                                                         
               3.  Whether petitioner’s filing status for 1998-2001 is                
          single.  We hold that it is.                                                
               4.   Whether petitioner may claim more than one personal               
          exemption for 1998-2001.  We hold that he may not.                          
               5.  Whether petitioner is liable for the additions to tax              
          under section 6651(a)(1) for failure to file and section 6654 for           
          failure to pay estimated tax for 1998-2001.  We hold that he is.            
               Section references are to the Internal Revenue Code in                 
          effect for the taxable years in issue.  Rule references are to              
          the Tax Court Rules of Practice and Procedure.                              






               1  Respondent does not contend that petitioner is liable for           
          the addition to tax for failure to file under sec. 6651(a)(1) in            
          an amount larger than respondent determined for any of the years            
          in issue.                                                                   




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