- 2 - related penalty under section 6662(a) for substantial understatement of income tax. Respondent reflected these determinations in a notice of deficiency issued to petitioner on December 18, 1995. Following respondent's concession of the addition to tax under section 6654(a), we must determine the following issues: 1. Whether petitioner's gross income includes his personal service income paid to a trust entitled Ideal Management.2 We hold it does. 2. Whether petitioner is liable for the accuracy-related penalty determined by respondent. We hold he is. 3. Whether petitioner is liable for a penalty under section 6673(a)(1). We hold he is liable for a penalty of $5,000. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and exhibits submitted therewith are incorporated herein by this reference. Petitioner resided in San Diego, California, when he petitioned the Court. He filed a 2 Although we use the word "trust" to refer to Ideal Management, we do not mean to suggest that Ideal Management is a trust for Federal income tax purposes. As discussed below, we conclude it is not. We use the word "trust" merely for convenience.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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