Edward J. Frami - Page 12

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               Respondent, for 1993 and 1994, also determined that                    
          petitioner was liable for self-employment tax and additions to              
          tax for failure to make estimated payments under section 6654.              
          Petitioner bears the burden of showing that part of respondent's            
          determination is in error.   Petitioner chose not to carry that             
          burden.  Accordingly, petitioner is liable for self-employement             
          tax and additions to tax for failure to make estimated payments             
          under section 6654 for his 1993 and 1994 taxable years.                     
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          



























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