Kenneth Siebert - Page 2

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                                        Additions to Tax                              
               Year      Deficiency     Sec. 6651(a)(1)    Sec. 6654                  
               1988      $33,616          $8,404            $330                      
               1989      44,162          10,972           2,966                       
               1990      8,376           2,094             551                        
               1991      8,766           2,192             504                        
               1992      8,815           2,204             384                        
               All section references are to the Internal Revenue Code in             
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
               The issues for decision are as follows:                                
               1.  Whether petitioner failed to report income for each year           
          in issue;                                                                   
               2.  whether petitioner, pursuant to section 1401, is liable            
          for self-employment tax;                                                    
               3.  whether petitioner, pursuant to section 6651(a)(1), is             
          liable for additions to tax for failure to file timely Federal              
          income tax returns; and                                                     
               4.  whether petitioner, pursuant to section 6654, is liable            
          for additions to tax for failure to make estimated tax payments.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          Petitioner resided in Plano, Texas, at the time his petition was            
          filed.                                                                      
          I.  Petitioner's Tax Consulting Practice                                    
               A.  In General                                                         
               During the years in issue, petitioner was a self-employed              
          tax consultant in Dallas, Texas.  Petitioner leased office space            



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