Daniel V. Presnick - Page 2

                                        - 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.                                                   

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