David D. Parrish - Page 2

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          1990      55,238         13,738         --             11,048               
          All section references are to the Internal Revenue Code in effect           
          for the years 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 failed to report income.  We hold               
          that he did.                                                                
               2.  Whether petitioner, pursuant to section 1366, is                   
          entitled to deduct losses relating to M&L Business Machine Co.,             
          Inc.  We hold that he is not so entitled.                                   
               3.  Whether petitioner, pursuant to section 1401, is liable            
          for self-employment tax.  We hold that he is liable to the extent           
          provided below.                                                             
               4.  Whether petitioner, pursuant to section 6651(a), is                
          liable for additions to tax for failing to file his tax returns             
          in a timely manner.  We hold that he is liable.                             
               5.  Whether petitioner, pursuant to sections 6653(a) and               
          6662(a), is liable for an addition to tax and accuracy-related              
          penalties for negligence.  We hold that he is liable.                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          Petitioner resided in Kearney, Nebraska, at the time his petition           
          was filed.                                                                  







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