- 2 - Respondent determined deficiencies and additions to tax in petitioner's Federal income taxes as follows: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1987 $3,276 $737 $178 1988 3,649 821 234 1989 3,948 888 267 1990 4,014 874 254 1991 4,099 923 235 1992 4,196 944 181 After trial respondent conceded that there are no deficiencies or additions to tax for the years 1987 and 1988. The issues remaining in dispute are: (1) Whether petitioner earned income in the amounts attributed to him in the notice of deficiency for the years 1989 through 1992; (2) if so, whether certain of that income is subject to the self-employment tax imposed by section 1401; (3) whether petitioner is liable for the addition to tax under section 6651(a) for each year due to his failure to file a Federal income tax return; and (4) whether petitioner is liable for the addition to tax under section 6654 for each year due to his failure to make estimated tax payments. Background Some of the facts have been stipulated, and they are so found. At the time that the petition was filed in this case, petitioner resided in St. George, Utah. Petitioner did not file a Federal income tax return or make any estimated Federal incomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011