Sid L. Marquis - Page 2

          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.            
               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                   

Page:  Previous  1  2  3  4  Next

Last modified: May 25, 2011