Jesse S. Frederick - Page 2

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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                   
               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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