- 2 -
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654
1988 $56,124 $13,966 $3,590
1989 33,575 8,394 2,270
1990 40,531 10,133 2,667
1991 100,185 25,046 2,589
1992 77,245 19,288 3,365
Following petitioner's concession that he is liable for the
deficiencies determined by respondent, we must decide whether he is
liable for the additions to tax as well. We hold he is. Unless
otherwise noted, section references are to the Internal Revenue
Code in effect for the years in issue. Rule references are to the
Tax Court Rules of Practice and Procedure.
Background
Petitioner resided in Guadalajara, Jalisco, Mexico, when he
petitioned the Court.
Petitioner was in the United States on a student visa for
approximately the 5-year period prior to 1988. During this period,
he performed personal services in the United States as an employee,
and Federal taxes were withheld from the corresponding paychecks
that he received. His visa expired in 1988, and he continued to
work and live in the United States from 1988 through 1992 without
official residency status.
Petitioner earned income in the United States during each of
the years from 1988 through 1992 performing services as a physician
on an independent contractor basis. He worked in various medical
facilities, most of which were located in or near Boston,
Massachusetts. Many of these facilities issued petitioner a Form
Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011