Helena Culver Fraser - Page 5

                                        - 5 -                                         
          circumstances, we will not look behind a notice of deficiency to            
          examine the evidence used by the Commissioner in her                        
          determination.  Id.                                                         
               Respondent considered reliable information that related to             
          petitioner in particular.  Attachments to the deficiency notice             
          identify petitioner's employers and other sources of income.                
          Nothing on the face of the notice of deficiency indicates that              
          respondent failed to make a determination with respect to                   
          petitioner's tax liability.  We find that respondent satisfied              
          the requirements of section 6212, and the notice of deficiency              
          issued to petitioner is valid.  Thus, we have jurisdiction over             
          this case.                                                                  
               Despite petitioner's extensive and well-written arguments on           
          brief, the factual allegations deemed admitted under Rule 91(f)             
          establish that petitioner had income for the years in issue which           
          she failed to report.  In addition, petitioner did not present              
          any evidence contesting respondent's determination that she is              
          subject to self-employment tax under section 1401.  We sustain              
          respondent's determination as to the deficiencies in petitioner's           
          Federal income and self-employment taxes.                                   
               Section 6654(a) imposes an addition to tax for failure to              
          make timely estimated income tax payments.  Section 6654(e)                 
          contains exceptions to the application of the addition to tax.              
          Petitioner bears the burden of proving that she is not liable for           
          additions to tax.  Rule 142(a).                                             

Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011