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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.
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Last modified: May 25, 2011