- 2 - 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 estimatedPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011