John Pryor Green - Page 2

                                        - 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 estimated                 




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