- 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