Wilburn C. Hall, Jr. - Page 2

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          2.  Held, further, P had unreported Schedule C gross                        
          receipts for 1982; amount determined.                                       
          3.  Held, further, P had unreported interest income for                     
          1984-1986; amounts determined.                                              
          4.  Held, further, P had unreported royalty income for                      
          1983, 1984, and 1986; P did not have unreported royalty                     
          income for 1985.                                                            
          5.  Held, further, expenses of corporations claimed on                      
          P's 1982-1986 tax returns are expenses of separate corporate                
          entities, and are not deductible by P.                                      
          6.  Held, further, amounts of deductions P is entitled                      
          to for 1982-1986 determined.                                                
          7.  Held, further, P is liable for self-employment                          
          taxes for 1983, 1985, and 1986.                                             
          8.  Held, further, P is liable for additions to tax                         
          under secs. 6651(a)(1), 6653(a), and 6661(a), I.R.C. 1954                   
          and 1986.                                                                   
          Wilburn C. Hall, Jr., pro se.                                               
          Edith F. Moates, for respondent.                                            

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
          CHABOT, Judge: Respondent determined deficiencies in                        
          Federal individual income tax and additions to tax under sections           
          6651 (a)(1)1 (failure to timely file tax returns), 6653(a)                  
          (negligence, etc.), and 6661(a) (substantial underpayment)                  
          against petitioner as follows:                                              



               1Unless indicated otherwise all chapter and section                    
          references are to chapters and sections of the Internal Revenue             
          Code of 1954, or the Internal Revenue Code of 1986, as in effect            
          for the respective years in issue; references to secs.6501 and              
          6212 are to these sections as in effect for notices of deficiency           
          mailed during 1990.                                                         



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