- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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