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petitioner's 1993 Federal income tax in the amount of $5,302 and
additions to tax pursuant to sections 6651(a) and 6654(a) in the
amounts of $1,326 and $224, respectively. The issues for
decision are: (1) Whether petitioner is liable for taxes on
nonemployee compensation and interest income earned by him in
1993; (2) whether petitioner is liable for additions to tax for
failure to file a return and failure to pay estimated tax; and
(3) whether petitioner is subject to a penalty under section
6673(a)(1).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Lakeland, Florida, at the time the petition was filed.
For the year ended December 31, 1993, petitioner earned the
following amounts of nonemployee compensation from the following
sources:
Source of Compensation Amount
Phoenix Home Life Mutual $918
Phoenix Home Life Mutual 5,703
Mutual of Omaha Insurance Co. 14,399
Protective Life Insurance Co. 924
Total 21,944
Petitioner earned the following amounts of interest from the
following sources during the year ended December 31, 1993:
1(...continued)
Tax Court Rules of Practice and Procedure.
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