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MEMORANDUM OPINION
NIMS, Judge:* By separate statutory notices of deficiency
issued on October 11, 1994, respondent determined the following
deficiencies in, and additions to, the Federal income tax of
Wayne D. Bumgarner (petitioner or Bumgarner):
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1987 $3,673 $393 $56
1991 814 100 --
1992 8,747 2,187 383
1993 12,351 3,088 581
Petitioner conceded all issues set forth in the notices of
deficiency, except the adjustments for wages and nonemployee
compensation, and the additions to tax under section 6651(a) for
failure to file returns for the taxable years in issue and
section 6654(a) for failure to pay estimated taxes for 1987,
1992, and 1993. Furthermore, petitioner conceded that he would
be liable for the additions to the tax under sections 6651(a) and
6654(a) if the Court were to hold that his wages and nonemployee
compensation are subject to income tax.
The sole remaining issue for decision is whether
petitioner's wages and nonemployee compensation should be
included in his gross income for income tax purposes for the
*This case was submitted to Judge Arthur L. Nims, III, by
Order of the Chief Judge.
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