- 2 - petitioner's liabilities for Federal income and self-employment taxes on unreported income and for additions to tax under sections 6651 and 6654. Respondent determined deficiencies and additions to tax with respect to petitioner's Federal income and self-employment taxes, as follows: Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1986 $16,505 $4,126 $ 796 1987 20,009 5,002 1,080 1988 17,234 4,309 1,102 1989 20,522 5,131 1,389 1990 15,886 3,972 1,045 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All figures are rounded. When the petition was filed, petitioner resided in Sedona, Arizona. For 1986 through 1990, petitioner failed to file Federal income tax returns. During audit, respondent reconstructed petitioner's taxable income for the years in issue using the bank deposits method. On October 10, 1995, respondent issued to petitioner a notice of deficiency with the above adjustments. On November 20, 1995, petitioner timely filed a petition for the years in issue. On January 22, 1996, respondent timely filedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011