- 2 - Procedure. Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a) Sec. 6654(a) 1989 $7,326 $1,832 $496 1990 6,326 1,582 416 1991 5,097 1,274 295 1992 4,501 1,125 193 After concessions by respondent,1 the issues for decision are: (1) Whether petitioner had unreported income for the years 1989, 1990, 1991, and 1992; (2) whether petitioner is liable for self-employment taxes for the years in issue; (3) whether petitioner is liable for additions to tax pursuant to section 6651(a)(1) for the years in issue; and (4) whether petitioner is liable for additions to tax pursuant to section 6654(a) for the years in issue. A few of the facts have been stipulated and are so found. Petitioner resided in Oakview, California, when he filed his petition. By letter dated April 1, 1994, Revenue Agent John F. Murphy informed petitioner that he had been identified as a nonfiling taxpayer and a participant in an organized movement named the Pilot Connection. The last record respondent had of a filed return from petitioner was for the year 1988. Petitioner was 1 Respondent concedes that petitioner's income for the years in issue, as determined by the Bureau of Labor Statistics data, should be reduced by the amounts attributed to petitioner as payments made for Social Security and Federal income taxes.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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