Richard T. Wallace - Page 2

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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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