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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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