- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011