-2-
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654(a)
1987 $3,446 $862 $186
1988 3,724 931 238
1989 5,137 1,284 347
The issues for decision are: (1) Whether petitioner earned
self-employment income2 during the 1987, 1988, and 1989 taxable
years in the amounts determined by respondent, and (2) whether
petitioner is liable for additions to tax under sections 6651 and
6654.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioner resided in
Morriston, Florida, at the time he filed his petition.
Background
In late 1978 or early 1979, petitioner started Fred Thomas
Tile Service, a sole proprietorship engaged in the installation
of ceramic tile for residences. Petitioner continued this
business during the years in issue and until its termination in
1993. Petitioner employed his brother, Lorenzo Thomas, as a tile
setter from early 1987 through late 1989. Petitioner continued
to manage the business during this time period.
2Petitioner has the burden of proving that any income he
received for his services related to work performed as an
employee rather than from self-employment. Green v.
Commissioner, T.C. Memo. 1996-107. Petitioner has not addressed
this issue. Consequently, to the extent we find that petitioner
received income for his services, such income is self-employment
income.
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