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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1987 $4,221 $1,055 $227
1988 3,750 938 241
1989 5,826 1,457 397
1990 5,587 1,397 367
1991 4,099 1,025 235
1992 4,109 1,027 180
Following concessions, we must decide:
1. Whether certain amounts paid to petitioner during the
subject years were taxable income. We hold they were.
2. Whether petitioner is subject to self-employment tax on
these amounts. We hold he is.
3. Whether petitioner is liable for the additions to tax
for delinquency determined by respondent under section
6651(a)(1). We hold he is.
4. Whether petitioner is liable for the additions to tax
for underpayments of estimated tax determined by respondent under
section 6654. We hold he is.
Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein. Petitioner resided in Miami, Florida, when
he petitioned the Court. He did not file income tax returns for
any of the subject years, and he did not make any estimated
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Last modified: May 25, 2011