Gerald Hickman - Page 2

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                                           Additions to Tax                           
                    Sec. Sec.      Sec.      Sec.      Sec.     Sec.                  
     Year  Deficiency  6651(a)(1)   6653(a)(1)    6653(a)(2)   6653(a)(1)(A)    6653(a)(1)(B)    6654
     1984   $3,727        $932       $186       1      --- ---     $234               
     1985    8,362 2,091        418       1      --- ---      479                     
     1986   10,690 2,673 ---      ---     $535  1      514                            
     1987   17,884 4,471 ---      ---      894  1      967                            
     1988   19,350 4,838 968      ---      ---  ---    1,237                          
          150 percent of the interest due on $3,727, $8,362, $10,690, and $17,884, respectively, for 1984
          through 1987.                                                               
          The determination is based on petitioner's failure to file                  
          Federal income tax returns and report income earned in his                  
          capacity as an independent contractor.1                                     
               Petitioner, while a resident of Clarkston, Michigan,                   
          petitioned the Court on December 26, 1996, to redetermine                   
          respondent's determination of deficiencies and additions to tax.            
          Petitioner concedes that he is liable for the tax deficiencies              
          and additions to tax for the 1984 through 1985 tax years.  The              
          1986 through 1988 tax years remain in issue, and we must decide             
          the following:                                                              
               1.  Whether respondent is collaterally estopped from                   
          asserting income tax deficiencies against petitioner for the 1986           
          through 1988 tax years.  We hold that respondent is not                     
          collaterally estopped from litigating this issue and that                   
          petitioner is liable for the entire deficiency determination.               




               1Unless otherwise indicated, section references are to the             
          Internal Revenue Code applicable to the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            





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