- 4 -
file a timely income tax return for 1993. Finally, the addition
to tax under section 6654(a) is based on respondent's
determination that petitioner failed to pay the requisite
estimated income tax for 1993.
Insofar as petitioner Linda L. Erwin is concerned, the
deficiency in income tax for 1993 is based on respondent's
determination that petitioner failed to report income from self-
employment, as reconstructed by respondent, on a timely filed
income tax return for that year. The deficiency in income tax
includes the self-employment tax. The addition to tax under
section 6651(a) is based on respondent's determination that
petitioner failed to file a timely income tax return for 1993.
Finally, the addition to tax under section 6654(a) is based on
respondent's determination that petitioner failed to pay
estimated income tax for 1993.
Petitioners' Petition at Docket No. 8625-953
Petitioners filed a petition for redetermination on May 24,
1995. In their petition, petitioners admit that "citizens and
resident aliens of the United States are taxed on all their net
3 The petition filed at docket No. 8626-95 by petitioner
Duane B. Erwin and the petition filed at docket No. 8627-95 by
petitioner Linda L. Erwin are virtually identical to the petition
filed by petitioners at docket No. 8625-95. Similarly, the
history of docket Nos. 8626-95 and 8627-95 subsequent to the
filing of the petitions parallels exactly the history of docket
No. 8625-95. Accordingly, we shall limit our discussion in this
Opinion to the petition filed at docket No. 8625-95. It should
be understood, however, that what we say in respect of that
docket applies equally to the other two dockets.
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