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All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
The issues for decision are: (1) Whether for 1993 and 1994
petitioner is properly subject to Federal income tax. We hold he
is. (2) Whether for 1993 and 1994 petitioner is liable for
additions to tax under section 6651(a). We hold he is. (3)
Whether for 1993 and 1994 petitioner is liable for additions to
tax under section 6654(a). We hold he is.
None of the facts have been stipulated.1 At the time the
petition in this case was filed, petitioner resided in Reno,
Nevada.
FINDINGS OF FACT
Petitioner did not file Federal income tax returns for the
taxable years 1993 and 1994.
In 1993, petitioner received nonemployee compensation from
M. Renken Distributing in the amount of $48,928, and gambling
winnings from Western Village Associates in the amount of $1,685.
In 1994, petitioner received nonemployee compensation from
M. Renken Distributing and Gordon Kinnaman in the amounts of
1Petitioner refused to sign any documents, claiming
protection under the Fifth Amendment to the U.S. Constitution.
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