Alan Michael Newman - Page 7

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          did, however, maintain a car during the years in issue, a 1979              
          Ford Pinto.                                                                 
               Petitioner has disproven that he had the additional income             
          determined by respondent by showing that his expenses were in               
          fact less than would be inferable from the Bureau of Labor                  
          Statistics' data and did not exceed the amounts of wages and                
          nonemployee compensation identified above.  Accordingly, we hold            
          that petitioner is not liable for the additional deficiencies               
          determined by respondent's utilizing Bureau of Labor Statistics'            
          data for the years in issue.                                                
               Issue 3.  Addition to Tax Under Section 6651(a)(1)                     
               Respondent determined an addition to tax under section                 
          6651(a)(1) for failure to file a return.  Petitioner did not file           
          Federal income tax returns for the years in issue.  Accordingly,            
          respondent's determination on this issue is sustained.                      
          Issue 4.  Addition to Tax Under Section 6654(a)                             
               Respondent determined an addition to tax under section                 
          6654(a) for underpayment of individual estimated tax.  Petitioner           
          failed to pay estimated tax during the years in issue.                      
          Accordingly, respondent's determination on this issue is                    
          sustained.                                                                  
               For the foregoing reasons,                                             


                                                  Decision will be entered            
                                             under Rule 155.                          



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