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3. Whether section 162 allows petitioner to claim
deductions for 1982 through 1988 for expenses incurred by
petitioner's alter ego corporations. We hold it does not.
4. Whether petitioner is liable for additions to tax for
failure to file under section 6651(a)(1) for 1982 through 1988.
We hold he is.
5. Whether petitioner is liable for additions to tax for
negligence under section 6653(a)(1) and (2) for 1982 through
1985, section 6653(a)(1)(A) and (B) for 1986 and 1987, and
section 6653(a) for 1988. We hold he is.
6. Whether petitioner is liable for additions to his 1982
through 1988 taxes under section 6654(a) for failure to pay
estimated taxes. We hold he is.
Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
Background
Some of the facts have been stipulated and are so found.
The stipulated facts and exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
Honolulu, Hawaii, when he petitioned the Court.
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