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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
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