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FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate the stipulation of facts by this reference.
Petitioner Robert Conrad Eanes II resided in Henderson,
Nevada, at the time the petition was filed. During the years at
issue, petitioner was self-employed and earned Schedule C, Profit
or Loss From Business, income in amounts sufficient to require
the filing of a Federal income tax return for each year at issue.
Petitioner, however, did not file a Federal income tax return or
an application for extension of time to file his Federal income
tax returns for any of the years at issue.
Using payor information returns (Forms 1099), respondent
reconstructed petitioner’s self-employment income and determined
that petitioner is liable for self-employment taxes as follows:
Net earnings
Sch. C from Self-employment
Year income self-employment tax
1990 $15,895 $14,679 $2,246
1991 46,477 42,922 6,567
1992 38,749 35,785 5,475
1993 35,394 32,686 5,001
1994 18,444 17,033 2,606
1995 53,671 49,565 7,583
1996 26,595 24,560 3,758
1997 68,000 62,798 9,608
Respondent issued a notice of deficiency for 1990 through 1993 on
March 19, 1999, and a notice of deficiency for 1994 through 1997
on March 24, 1999.
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Last modified: May 25, 2011