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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1990 $9,318 $2,330 $610
1991 7,110 1,778 406
Respondent subsequently filed an amendment to answer,
asserting increased deficiencies and additions to tax to the
following amounts:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1990 $33,544 $8,386 $2,209
1991 29,402 7,351 1,691
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
The issues for decision are: (1) Whether petitioner failed
to report income for 1990 in the amount of $92,656; (2) whether
petitioner failed to report income in 1991 in the amount of
$78,996; (3) whether petitioner is liable for self-employment
taxes in the amounts of $7,849 and $9,038 for the years 1990 and
1991, respectively; (4) whether petitioner is subject to
additions to tax for failure to file Federal income tax returns
for the years 1990 and 1991; and (5) whether petitioner is liable
for additions to tax for failure to make estimated tax payments
for the taxable years 1990 and 1991.
FINDINGS OF FACT
Petitioner was a resident of California at the time the
petition herein was filed. Petitioner did not file Federal
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