Duane B. and Linda L. Erwin, et al. - Page 4

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            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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