- 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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