Hans C. Sherrer - Page 3




                                         -3-                                          
               We sustain all of respondent's determinations, except that             
          we allow additional deductions, in amounts less than those                  
          claimed by petitioner, for the years 1990-92 for business                   
          expenses paid in cash, resulting in corresponding adjustments to            
          the income tax deficiencies and the additions to tax for those              
          years.                                                                      

                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated and are so found; the           
          stipulation of facts and related exhibits are incorporated by               
          this reference.                                                             
               Petitioner resided in Vancouver, Washington, at the time the           
          petition was filed.                                                         
               Petitioner worked as a plumber and plumbing subcontractor              
          during each of the years in issue (1989-94).  Petitioner                    
          conducted this business as a sole proprietorship under the name             
          "Down to Earth Plumbing".                                                   
               Petitioner earned gross income from his plumbing business in           
          each of the years in issue, and his petition acknowledges that he           
          had taxable income (and still owes tax) for each of those years.            
          Nevertheless, petitioner did not file income tax returns for any            
          of the years in issue.  In addition, as of February 1998, no                
          payments or credits had been made to petitioner's income tax                
          account for the years in issue, other than a few small payments             
          in 1996.                                                                    





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