Said Mahmoud Karara - Page 9




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          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 file                 





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