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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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