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year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure. The issues for decision are as
follows:
1. Whether petitioner is liable for the deficiency
determined by respondent. We hold that he is liable.
2. Whether petitioner, pursuant to section 6651(a)(1), is
liable for an addition to tax for failing to file his 1991
Federal income tax return in a timely manner. We hold that he is
liable.
3. Whether petitioner, pursuant to section 6654, is liable
for an addition to tax for failing to make estimated tax
payments. We hold that he is liable.
4. Whether petitioner has engaged in behavior that warrants
the imposition of a penalty pursuant to section 6673(a)(1). We
hold that a penalty is warranted and impose a penalty of $5,000.
FINDINGS OF FACT
At the time the petition was filed, petitioner resided in
Medfield, Massachusetts. In 1991, petitioner received $52,568
for services rendered to New England Retail Express, Inc. He did
not file a 1991 Federal income tax return.
On February 27, 1996, respondent issued a notice of
deficiency to petitioner. In it, respondent determined that
petitioner, with respect to his 1991 tax year, was liable for a
deficiency and additions to tax pursuant to sections 6651(a)(1)
and 6654. Respondent mailed the notice to petitioner's residence
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