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Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether petitioner is
liable for additions to tax under section 6653(a)(1) and (2). We
hold that he is. (2) Whether petitioner is liable for an addition
to tax under section 6661(a). We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
At the time the petition was filed, petitioner resided in
New York, New York.
Petitioner received a bachelor of science degree from
Trinity University of Texas in 1978. In 1983, petitioner was
employed as an art director by Marsteller Inc. and also did
graphic design and advertising work for Gorman-Glassberg, Inc.
Also during 1983, petitioner ran a sole proprietorship providing
freelance work in the field of graphic design and advertising
from which he reported gross receipts of $49,983 and a net profit
of $23,190. Petitioner was 26 years old in 1983.
Petitioner's return was prepared by Nicholas J. Coscia, an
accountant with Coscia and Amsterdam. At this time, Mr. Coscia
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