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All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
The issues for decision are: (1) Whether for 1990, 1991,
and 1993 petitioner received and failed to report wages and
nonemployee compensation of $9,130, $12,158, and $22,927,
respectively. We hold he did. (2) Whether for 1990, 1991, and
1993 petitioner received and failed to report additional income
of $21,178, $19,771, and $10,913, respectively. We hold he did
not. (3) Whether for 1990, 1991, and 1993 petitioner is liable
for an addition to tax pursuant to section 6651(a)(1). We hold
he is. (4) Whether for 1990, 1991, and 1993 petitioner is liable
for an addition to tax pursuant to section 6654(a). We hold he
is.
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. At the time the petition
in this case was filed, petitioner resided in Santa Clara County,
California.
FINDINGS OF FACT
During 1990, petitioner was employed by C.K. Trucking and
received wages and nonemployee compensation of $7,855 and $1,275,
respectively.
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