Randolph John Beale - Page 3




                                                - 3 -                                                  
            under section 6651(a)2 for failure to timely file his Federal                              
            income tax returns for the taxable years in issue.  We hold he                             
            is.  (6) Whether petitioner is liable for additions to tax under                           
            section 6654 for failure to pay estimated tax for the taxable                              
            years in issue.  We hold he is.                                                            
                                         FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are so found.                             
            The stipulation of facts and the attached exhibits are                                     
            incorporated herein by this reference.  At the time the petition                           
            herein was filed, petitioner resided in Chuluota, Florida.                                 
                  Petitioner did not file Federal income tax returns for the                           
            years in issue.                                                                            
                  At various times during the years in issue, petitioner was                           
            employed full time as an engineer for the following companies:                             
            Linde Hydraulics Corp. (Linde), Hartmann Controls, Inc.                                    
            (Hartmann), Motiontek, Inc. (Motiontek), and Worksmart, Inc.                               
            (Worksmart).  Petitioner earned income from his full-time                                  
            employment as follows:                                                                     








                  2Unless otherwise indicated, all section references are to                           
            the Internal Revenue Code in effect for the years at issue, and                            
            all Rule references are to the Tax Court Rules of Practice and                             
            Procedure.                                                                                 




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