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Respondent determined a deficiency in petitioner's 1989
Federal income tax in the amount of $6,892, an addition to tax
under section 6651(a)(1) in the amount of $1,723, and an addition
to tax under section 6654 in the amount of $467. The issues for
decision are: (1) Whether the period of limitations prohibits
the assessment and collection of the deficiency here in dispute;
if not, (2) whether petitioner received and failed to report
certain income attributed to him in the notice of deficiency; (3)
whether petitioner is entitled to claim certain deductions; (4)
whether petitioner is liable for the section 6651(a)(1) addition
to tax for failure to file a return for 1989; and (5) whether
petitioner is subject to the addition to tax under section 6654
for failure to pay estimated income tax.
Background
Some of the facts have been stipulated and are so found.
Petitioner resided in Little Rock, Arkansas, during all relevant
periods, including when the petition was filed in this case.
Except for a brief period during 1987 or 1988, from 1984
through at least some portion of 1989, petitioner was employed as
a salesperson for Swink and Company, Inc. (Swink), an investment
banking firm. Swink was forced into bankruptcy sometime in 1989
and went out of business by the end of that year.
While employed by Swink, petitioner was compensated on a
commission basis. For the year 1989, petitioner received at
least $38,304 in compensation from Swink, as reflected on a Form
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Last modified: May 25, 2011