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petitioner is liable for the deficiencies resulting from
unreported ordinary income as determined by respondent and from
unreported capital gain in accordance with our findings. In
addition, we find that petitioner is liable for self-employment
taxes as determined by respondent and for additions to tax for
failure to file and failure to pay estimated tax in accordance
with our findings.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011