Kenneth W. Diercks - Page 2

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          1989       9,958             2,490               674                        
          1990       9,665             2,416               636                        
          1991       7,204             1,801               412                        
          1992       5,674             1,419               247                        
               The issues for decision are:                                           
               (1) Did petitioner have unreported income for each of the              
          years at issue?  We hold that he did.                                       
               (2) Is petitioner liable for self-employment tax for each              
          of the years at issue?  We hold that he is.                                 
               (3)  Is petitioner liable for the addition to tax under                
          section 6651(a)(1) for each of the years at issue?  We hold that            
          he is.                                                                      
               (4) Is petitioner liable for the addition to tax under                 
          section 6654(a) for each of the years at issue?  We hold that he            
          is.                                                                         
               Petitioner resided at Sparks, Nevada, at the time the                  
          petition was filed.                                                         
               Petitioner did not file a U.S. income tax return for any of            
          the years 1987 through 1992.                                                
               During the years 1987 through 1992, petitioner worked and              
          earned income.  However, he failed to keep records of the type or           
          amount of work he performed, or of the amount of income he                  
          received from his work, during those years.                                 
               During the years at issue, petitioner was married and had              
          three children who lived with him and his wife, Bonnie Diercks              
          (Ms. Diercks), at their residence (residence) and who attended              





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