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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1989 $85,477 $21,369 $808
1990 160,895 40,224 10,595
1991 20,170 5,043 1,162
1992 67,450 16,863 2,940
1993 86,128 21,408 3,606
Unless otherwise noted, 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.
We must decide whether petitioner is liable for Federal
income taxes and additions to tax. We hold that he is, to the
extent set out below.
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts,
supplemental stipulation of facts, second supplemental
stipulation of facts, and attached exhibits. At the time of
filing the petition, petitioner resided in Soquel, California.
The facts are not in dispute. Petitioner failed to report
any income during the years in issue. Respondent’s
determinations in the notice of deficiency were based on
petitioner’s unreported income comprising the following:
Dividends and interest, wages, self-employment compensation, and
capital gain. At trial, respondent presented substantial
evidence in support of the determinations. Petitioner has
admitted to receiving the ordinary income. With respect to the
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