Gregory Harris Sims - Page 2

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               We must decide the following issues with respect to 1989:              
               1.  Whether petitioner failed to report $66,851 of wages               
          paid to him by his wholly owned corporation.                                
               2.  Whether petitioner may deduct mortgage interest in an              
          amount greater than allowed by respondent in the notice of                  
          deficiency.                                                                 
               3.  Whether petitioner is liable for the addition to tax for           
          late filing determined by respondent under section 6651(a)(1).              
               4.  Whether petitioner is liable for the accuracy-related              
          penalty determined by respondent under section 6662(a).                     
               We hold for respondent on all issues.  Section references              
          are to the Internal Revenue Code in effect for the year in issue.           
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and exhibits submitted therewith are                   
          incorporated herein by this reference.  Petitioner resided in               
          Los Angeles, California, when he petitioned the Court.                      
               Petitioner did not file a 1989 Federal income tax return               
          until August 2, 1993.  Petitioner's 1989 tax return (Form 1040,             
          U.S. Individual Income Tax Return), which was prepared by                   
          Nugit & Licker, C.P.A.'s on July 7, 1993, reported that                     
          petitioner received $54,250 of gross receipts from his sole                 






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