John Wadsworth - Page 2

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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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