- 2 - Additions to Tax Year Deficiency Sec. 6651(a)(1)1 Sec. 6654 1990 $5,472 $1,368 --- 1991 5,675 1,419 $324 1992 5,869 1,467 256 1993 6,124 612 257 The issues for decision are: (1) Whether petitioner received taxable income in the amounts determined by respondent during the years 1990 through 1993; (2) whether petitioner is liable for self-employment taxes for each of the years 1990 through 1993; (3) whether petitioner is liable under section 6651(a) for the additions to tax for failure to file Federal income tax returns for each of the years 1990 through 1993; and (4) whether petitioner is liable under section 6654 for the additions to tax for failure to make estimated tax payments for each of the years 1991 through 1993. This case was submitted with the facts fully stipulated under Rule 122. The stipulation of facts and the exhibits attached thereto are incorporated herein by reference. The pertinent facts are summarized below. Petitioner resided in Boulder, Colorado, at the time his petition was filed in this case. He filed no Federal income tax 1 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, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011