Keith R. Basham - Page 2

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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.                                    
               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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