- 2 - Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax for the years indicated: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1990 $2,699 $674.75 - 1991 1,420 355.00 $82.00 1992 1,822 455.50 79.00 1993 1,224 288.25 47.99 After concessions by the parties,2 the issues remaining for decision are: (1) Whether petitioner had unreported nonemployee compensation in amounts determined by respondent; (2) whether petitioner is liable for the section 6651(a)(1) additions to tax; (3) whether petitioner is liable for the section 6654(a) additions to tax. No stipulations of fact were filed in this case. Petitioner resided in Orange, Connecticut, on the date the petition was filed in this case. Petitioner is a former member of the Connecticut State Bar, having been disbarred in 1989. He worked as a property manager for Florida Realty and Reconstruction, Inc. (Florida Realty) during the taxable years in issue. He was responsible for managing one rental property, located in Guilford, Connecticut, which he described as a "giant house". Florida Realty is 2 Respondent concedes that petitioner's nonemployee compensation for taxable year 1990 is only $5,637, approximately half of the amount determined in the statutory notice of deficiency. Petitioner concedes that he received and failed to report interest income and dividend income in the amounts determined by respondent.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011