Randal W. Howard - Page 2

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                   Additions to Tax                                                   
          Sec.          Sec.        Sec.                                              
          Year     Deficiency    6651(a)(1)     6653(a)*     6654(a)                  
          1987       $3,858       $  964.50     $192.90      $208.36                  
          1988        5,298        1,324.00      265.00       339.00                  
               * For 1987, the addition to tax is under sec. 6653(a)(1)(A)            
          and, additionally, under sec. 6653(a)(1)(B) for 50 percent of the           
          interest due on the underpayment of $3,858.  For 1988, the                  
          addition to tax is under sec. 6653(a)(1).                                   

               The issues for determination are:  (1) Whether petitioner is           
          liable for the deficiencies in tax based upon amounts reported by           
          payers as having been paid to petitioner during the years in                
          question, and (2) whether petitioner is liable for the additions            
          to tax.                                                                     
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are incorporated herein by               
          reference.  At the time the petition was filed, petitioner's                
          residence was in the State of Arizona.                                      
               In the notices of deficiency, respondent determined, based             
          upon information reported by payers, that petitioner earned the             
          following income during the years in question:                              

          1987       1988                                                             
          Family Life Broadcast               $16,799    $19,938                      
          Arizona Central (interest)               73         12                      
          Grace Broadcasting                     --        1,600                      
          Total                             $16,872    $21,550                        

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