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Petitioner did not timely file his Federal income tax return
for the year at issue. He filed his return for 1992 after the
notice of deficiency was issued. In the notice of deficiency,
respondent determined that petitioner had unreported income of
$43,380 and unreported nonemployee compensation income of $1,951,
both from the tribal council. Respondent further determined that
petitioner had unreported interest income of $98 from Norwest
Bank, and that he was liable for self-employment taxes of $275.5
Respondent allowed petitioner a self-employment tax deduction of
$138, a standard deduction of $3,600, and one personal exemption
of $2,300. Respondent also determined that petitioner was liable
for additions to tax under section 6651(a)(1) for failure to
timely file a Federal income tax return, section 6651(a)(2) for
failure to timely pay the amount shown as tax on the return, and
section 6654(a) for failure to make estimated tax payments, in
the amounts of $1,915, $681, and $374, respectively.
In a Stipulation of Settled Issues filed with the Court at
trial, petitioner conceded that the nonemployee compensation of
$1,951 from the tribal council and the interest income of $98
from Norwest Bank were includable in gross income for 1992.
Further, petitioner conceded that he was liable for self-
5
All the unreported income adjustments were based on
information reported to respondent by third party payers.
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