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Within 60 days of making the jeopardy assessment, respondent
determined deficiencies in, and additions to, petitioner's
Federal income tax for 1991, 1992, and 1993 as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1991 $5,957 $1,489 $344
1992 24,457 6,114 1,069
1993 28,416 7,104 1,191
The issues for decision are: (1) Whether respondent's notice
of deficiency was arbitrary. We hold it was not. (2) Whether
petitioner has unreported income for the tax years 1991, 1992,
and 1993. We hold he does, to the extent set out below. (3)
Whether petitioner is liable for self-employment tax for 1991,
1992, and 1993. We hold he is. (4) Whether petitioner is liable
for an addition to tax under section 6651(a)(1)1 for 1991, 1992,
and 1993 for failure to file Federal income tax returns. We hold
he is, to the extent set out below. (5) Whether petitioner is
liable for an addition to tax under section 6654 for 1991, 1992,
and 1993 for the failure to make estimated tax payments. We hold
he is, to the extent set out below.
1 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, unless otherwise
indicated. All dollar amounts are rounded to the nearest dollar,
unless otherwise indicated.
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