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Additions to Tax
Section Section
Year Deficiency 6651(a)2 6654
1987 $4,449 $1,112 $270
1988 3,155 789 202
1989 3,963 991 268
1990 4,044 1,011 265
The issues for decision are:
(1) Did petitioner have income for each of the years at
issue in the amounts determined by respondent? We hold that he
did.
(2) Is petitioner entitled to deductions and/or exemptions
for any of the years at issue in excess of those allowed by
respondent? We hold that he is not.
(3) Is petitioner liable for self-employment tax for each
of the years at issue? We hold that he is.
(4) Is petitioner liable for the addition to tax for
failure to file for each of the years at issue? We hold that he
is.
(5) Is petitioner liable for the addition to tax for
failure to make estimated tax payments for each of the years at
issue? We hold that he is.
Background
Petitioner's address as indicated in the petition he filed
2 All sections references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011