- 2 - 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 atPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011