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Additions to Tax
Sec. Sec.
Year Deficiency 6651(f) 6654
1992 $12,153 $7,214 $123
1993 36,489 26,892 1,499
1994 55,518 41,639 2,860
Respondent also determined that petitioner is liable for
additions to each year's tax under section 6651(a), to the extent
that he is not liable for the additions to tax under section
6651(f).
We must decide the following issues:
1. Whether petitioner received $25,742 and $6,540 of wages
in 1992 and 1993, respectively, as determined by respondent. We
hold he did.
2. Whether petitioner received $23,892, $101,164, and
$151,548 of gross receipts in 1992 through 1994, respectively, as
determined by respondent. We hold he did.
3. Whether petitioner is liable for the additions to tax
for fraudulent failure to file determined by respondent under
section 6651(f). We hold he is.1
4. Whether petitioner is liable for the additions to tax
for failure to pay estimated tax determined by respondent under
section 6654. We hold he is.
1 Thus, we do not decide respondent's alternative
determination under sec. 6651(a).
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Last modified: May 25, 2011