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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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