Willie Thomas - Page 2

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                                                         Additions to Tax                                                        
                                Sec.         Sec.          Sec.             Sec.            Sec.                                 
               Year   Deficiency   6653(b)(1)   6653(b)(2)   6653(b)(1)(A)   6653(b)(1)(B)      6661(a)                          
               1984   $78,807.11   $39,403.56       1             --              --          $19,701.78                         
               1985    41,092.63    20,546.32       2             --              --           10,273.16                         
               1986    36,949.80       --           --       $27,712.35           3             9,237.45                         
               1987    16,621.39       --           --        12,466.04           4             4,155.35                         

                    1 50 percent of the statutory interest on $78,807.11, computed from Apr. 15, 1985, to the                    
               earlier of the date of assessment or the date of payment.                                                         
                    2 50 percent of the statutory interest on $41,092.63, computed from Apr. 15, 1986, to the                    
               earlier of the date of assessment or the date of payment.                                                         
                    3 50 percent of the statutory interest on $36,949.80, computed from Apr. 15, 1987, to the                    
               earlier of the date of assessment or the date of payment.                                                         
                    4 50 percent of the statutory interest on $16,621.39, computed from Apr. 15, 1988, to the                    
               earlier of the date of assessment or the date of payment.                                                         

                    Unless otherwise indicated, all section references are to the                                                

               Internal Revenue Code in effect for the years in issue, and all                                                   

               Rule references are to the Tax Court Rules of Practice and                                                        

               Procedure.                                                                                                        

                    The issues for decision are as follows:                                                                      

                    1.  Whether petitioner failed to report income in 1984, 1985,                                                

               1986, and 1987.  We hold that he failed to report income.                                                         

                    2.  Whether petitioner, pursuant to section 1401, is liable                                                  

               for self-employment tax.  We hold that he is liable.                                                              

                    3.  Whether petitioner, pursuant to section 6653(b), is                                                      

               liable for additions to tax for fraud.  We hold that he is liable                                                 

               to the extent stated herein.                                                                                      

                    4.  Whether petitioner, pursuant to section 6661(a), is                                                      

               liable for additions to tax for substantial understatements of                                                    

               tax.  We hold that he is liable.                                                                                  













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