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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.
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