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Net income from
Year self-employment Wages Interest
1987 $21,828
1988 32,277 1$1,530
1989 56,581
1990 37,609 2375 3$61
1991 50,669
1992 78,645
1 paid by Swimmin' Time, Inc.
2 paid by Dennis G. Hann
3 paid by Arizona Central Credit Union
The deficiencies in income taxes include self-employment taxes under section
1401.
The additions to tax under section 6651(a)(1) are based on respondent's
determination that petitioner's failure to file income tax returns for the
years in issue was not due to reasonable cause. The additions to tax under
section 6653(a)(1)(A) and (B) for 1987 and the addition to tax under section
6653(a)(1) for 1988 are based on respondent's determination that the
underpayment for each of those years is due to negligence or intentional
disregard of rules or regulations. Finally, the additions to tax under
section 6654(a) are based on respondent's determination that petitioner failed
to pay sufficient estimated income taxes for 1988 and 1990 and failed to pay
any estimated income taxes for the remaining years in issue.
Petitioner's Petition
Petitioner filed a petition for redetermination on May 25, 1995. The
petition contained no assignments of error or allegations of fact. The only
statement in the petition that is directed at respondent's deficiency
determination reads as follows: "Notice of Deficiency is without merit as it
is based on Fraudulent IRS Individual Master File kept on the petitioner by
the IRS".
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Last modified: May 25, 2011