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Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6654
1992 $20,915 $15,686 $139
1993 22,318 16,739 935
1994 23,649 17,737 1,218
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.
When Mr. Allen filed his petition, on February 24, 1997, he
resided in Kent City, Michigan. In his petition, Mr. Allen
contested all of respondent's determinations. Mr. Allen has the
burden of proving that respondent's determinations of income tax
deficiencies and additions to tax under section 6654 are
erroneous. He refused, however, to stipulate any facts, appear
at trial, or submit a brief.
Prior to 1992, Mr. Allen filed timely Federal income tax
returns. Mr. Allen did not, however, file returns or pay
estimated taxes relating to 1992, 1993, and 1994. During these
years, Mr. Allen operated a sole proprietorship which designed
and manufactured electric controls. After conducting an audit
and reconstructing Mr. Allen's income from bank records,
respondent determined that Mr. Allen is liable for income and
self-employment taxes relating to 1992, 1993, and 1994. Mr.
Allen, however, did not present any evidence relating to these
issues. Accordingly, we sustain respondent's determinations.
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Last modified: May 25, 2011