respectively. Respondent also determined additions to tax for
the years 1990 and 1991 under section 6651(a)(1) in the amounts
of $540 and $1,594, respectively, and under section 6654 in the
amounts of $76 and $365, respectively.
The issues for decision are: (1) Whether petitioner had
unreported income in both years at issue; (2) whether petitioner
failed to file timely Federal income tax returns for 1990 and
1991; and (3) whether petitioner underpaid his estimated taxes
for the years 1990 and 1991.
A few of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. Petitioner lived in
Sparks, Nevada, at the time the petition in this case was filed.
Background
Petitioner did not file Federal income tax returns for 1990
and 1991 based upon his beliefs and his determination that he was
not liable for any tax.
During the years under consideration, petitioner lived in
San Diego, California. Petitioner was employed by Hawthorne
Machinery Co. (Hawthorne) in 1990 and was paid for his work.
Copies of payroll checks to petitioner from Hawthorne in 1990
totaling $23,325.592 were received into evidence. Petitioner
worked for Hawthorne for 3 months in 1991. Copies of payroll
2The statutory notice of deficiency makes an adjustment to
petitioner's income for 1990 in the amount of $28,287 for
"wages".
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