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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined deficiencies and
additions to tax for 1990, 1991, and 1992 with respect to
petitioner's Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1990 $17,238 $4,310 $1,129
1991 33,970 8,493 1,941
1992 40,711 10,178 1,776
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. All dollar amounts are rounded to the
nearest dollar.
After concessions made by petitioner, the issues for
decision are: (1) Whether petitioner had unreported gross
receipts from her sole proprietorship, as determined by
respondent, for her 1990, 1991, and 1992 taxable years; (2)
whether petitioner is liable for the addition to tax under
section 6651(a)(1) for the failure to file timely tax returns for
the years in issue; and (3) whether petitioner is liable for the
addition to tax under section 6654(a) for the failure to pay
estimated income taxes for the years in issue.
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