- 2 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011