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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated March 31,
1997 (the deficiency notice), respondent determined deficiencies
in petitioner's Federal income taxes and addition to tax, and
accuracy-related penalties as follows:
Addition to tax Accuracy-related
Year Deficiency Sec. 6651(a)(1) penalty Sec. 6662(a)
1992 $19,276 -- $3,816
1993 5,811 $486 1,162
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The parties have filed a stipulation of settled issues, in
which petitioner concedes certain issues. Those concessions are
accepted. The issues remaining for decision are: (1) Whether
petitioner omitted from gross income $25,000 and $21,250 for 1992
and 1993, respectively, (2) whether those amounts constitute
income from self-employment, and (3) whether petitioner is liable
for accuracy-related penalties for both 1992 and 1993 on account
of negligence or disregard of rules or regulations.
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