Larry L. Bennett - Page 2

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                                              Additions to Tax                        
                                                 Sec.            Sec.                 
                Year         Deficiency       6651(a)(1)         6654                 
                1987           $15,678        $3,919.50         $841.61               
                1988           15,435         3,858.75          992.88                
                1989           16,301         4,075.25         1,102.42               
                1990           16,721         4,180.25         1,094.74               
                1991           17,410         4,352.50          994.99                
                1992           18,145         4,536.25          791.41                
                1993           19,059         4,764.75          798.56                
               All section references are to the Internal Revenue Code in             
          effect for the taxable years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure, unless                
          otherwise indicated.                                                        
               The issues for decision are: (1) Whether petitioner earned             
          income during the years 1987 through 1993 in the amounts deter-             
          mined by respondent; (2) whether petitioner is liable for self-             
          employment taxes as determined by respondent; (3) whether peti-             
          tioner is entitled to deductions in excess of those determined by           
          respondent; (4) whether petitioner is liable for the additions to           
          tax provided by section 6651(a)(1) for failure to timely file a             
          Federal income tax return; and, (5) whether petitioner is liable            
          for the additions to tax provided by section 6654(a) for failure            
          to make estimated tax payments.                                             
          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and attached exhibits are                  
          incorporated herein by this reference.  During the years at                 




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