Joseph T. McQuatters - Page 2

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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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