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Respondent determined deficiencies in petitioner's Federal
income taxes and additions to tax for the years as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1991 $850 $212.50 ---
1992 832 208.00 $36.27
1993 872 218.00 36.54
1994 883 220.75 45.85
The issues for decision are: (1) Whether petitioner
received and failed to report income during the taxable years in
issue; (2) whether petitioner is liable for the section
6651(a)(1) additions to tax for failure to file his returns for
the taxable years in issue; (3) whether petitioner is liable for
the section 6654(a) additions to tax for failure to make
estimated income tax payments for 1992, 1993, and 1994; and (4)
whether we should impose a penalty on petitioner pursuant to
section 6673(a).
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Grimstead,
Virginia, on the date the petition was filed in this case.
Petitioner did not file Federal income tax returns for the
taxable years in issue. He was a 50-percent partner in Forrest
Seafood Company (FSC) during the taxable years in issue. He
received guaranteed payments from FSC which he has stipulated
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011