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Earnest Tillman petitioned the Court to redetermine
respondent’s determination of a deficiency in his 1990 and 1991
Federal income taxes and additions thereto under sections
6651(a)(1) and 6654. Respondent reflected this determination in
a notice of deficiency issued to Earnest Tillman on April 26,
1994.
The notices of deficiency show the following deficiencies,
additions to tax, and penalty:
Earnest and Laura Tillman, docket No. 4281-94
Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1989 $27,770 $6,967 $5,057
Earnest Tillman, docket No. 13423-94
Additions to Tax
Year Deficiencies Sec. 6651(a)(1) Sec. 6654
1990 $33,203 $8,301 $2,179
1991 53,119 13,280 3,046
In an amendment to her answer, respondent alleges that
Mr. Tillman is liable for deficiencies for 1990 and 1991, greater
than those amounts shown in the corresponding notice. The
greater deficiencies, respondent states, stem from: (1) An
insurance payment that Mr. Tillman received in 1990 to cover the
theft of his fully depreciated truck, and (2) moneys that
Mr. Tillman received in 1990 and 1991, for sales that he did not
report on his Schedules C, Profit or Loss From Business. The
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