Alan Michael Newman - Page 2

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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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