Don H. Wisden - Page 2

                                        - 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 income            





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011