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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 filed
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