- 9 - and that the taxpayer's primary purpose for engaging in the activity must be for income or profit." Petitioner did not establish that he was engaged in a trade or business during 1993 and 1994. Petitioner earned no gross receipts from the purported activity during the 2 years at issue and presented no documentary information to establish exactly what type of an activity he was purportedly engaged in. He testified he was engaged in an engineering activity but presented no evidence as to the nature of the engineering services he provided, the nature of his clients, the date the activity commenced, and why, during 1993 and 1994, he had no gross income from such an activity. Petitioner testified he had an engineering background and had taught engineering at two or three colleges, and, although the Court has no reason to doubt such testimony, the Court is not satisfied that petitioner's background established a trade or business during 1993 and 1994. On this record, the Court holds that petitioner failed to establish that he was engaged in a trade or business activity during 1993 and 1994. 4. Sec. 6651(a) Failure-to-File Addition to tax The next issue is whether petitioner is liable for the additions to tax under section 6651(a)(1) for his failure to file Federal income tax returns for 1993 and 1994. Section 6651(a)(1) imposes an addition to tax for a taxpayer's failure to filePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011