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On the record before us, we find that petitioner failed to
prove error in respondent's determinations that he had income in
the amounts determined in the notice for each of the years 1987
through 1992. We further find on that record that petitioner
failed to show that he is not liable for each of the years at
issue for (1) the addition to tax under section 6651(a)(1),
(2) the addition to tax under section 6654(a), and (3) self-
employment tax, as determined in the notice. Accordingly, we
sustain respondent's determinations in the notice.
To reflect the foregoing,
Decision will be entered
for respondent.
2(...continued)
Ms. Diercks shows that Ms. Diercks received wages of only $6,362
for 1989 or approximately $530 a month during that year.
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