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All Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a deficiency in petitioner's 1988
Federal income tax in the amount of $4,965 and additions to tax
for failure to file timely a Federal income tax return pursuant
to section 6651(a)(1) in the amount of $1,241 and for failure to
pay estimated taxes pursuant to section 6654(a) in the amount of
$318.
We must decide the following issues:
1. Whether petitioner received nonemployee compensation in
the amount of $20,309 from Masterguard Corp. in 1988 as
determined by respondent. We hold he did.
2. Whether petitioner received interest income in the
amount of $128 from Lexington State Bank in 1988 as determined by
respondent. We hold he did.
3. Whether petitioner is liable for self-employment tax in
1988 in the amount of $2,644 as determined by respondent. We
hold he is.
4. Whether petitioner is liable for an addition to tax
under section 6651(a)(1) for failure to file an income tax
return. We hold he is.
5. Whether petitioner is liable for an addition to tax for
the failure to pay estimated tax as determined by respondent
under section 6654(a). We hold he is.
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