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All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
The issues for decision after concessions by the parties
are:
1. Whether petitioner is liable for tax on income arising
from nonemployee compensation for the 1989, 1990, 1991, and 1992
tax years. We hold that he is.
2. Whether petitioner is liable for self-employment tax on
his nonemployee compensation during the 1989, 1990, 1991, and
1992 tax years. We hold that he is.
3. Whether petitioner is liable for additions to tax under
section 6651(a)(1) for failure to file for the 1989, 1990, 1991,
and 1992 tax years. We hold that he is.
4. Whether petitioner is liable for additions to tax under
section 6654 for failure to pay estimated tax for the 1989, 1990,
1991, and 1992 tax years. We hold that he is.
5. Whether petitioner is liable for a penalty under section
6673. We hold that he is.
Some of the facts have been stipulated. The stipulation of
facts and the attached exhibits are incorporated herein by this
reference. At the time he filed his petition, petitioner resided
in Branson, Missouri. Petitioner was married at all times during
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