Russell S. Greene - Page 2




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               Russell S. Greene, pro se.                                                
               Mark A. Weiner, for respondent.                                           


                                   MEMORANDUM OPINION                                    

               NIMS, Judge:  Respondent determined the following                         
          deficiencies and additions to tax with respect to petitioner’s                 
          Federal income taxes for the taxable years 1992 through 1996:                  

                  Taxable              Income Tax          Addition to Tax               
                   Year                Deficiency          Sec. 6651(a)(1)               
                   1992                  $4,494                 $1,020                   
                   1993                  3,757                  730                      
                   1994                  9,079                  2,180                    
                   1995                  7,764                  1,914                    
                   1996                  7,121                  1,378                    
               After concessions, the issues remaining for decision are:                 
               (1) Whether petitioner failed to report income from wages,                
          nonemployee compensation, interest, dividends, and capital gain                
          upon which petitioner is liable for individual Federal income                  
          taxes;                                                                         
               (2) whether petitioner is liable for self-employment taxes                
          pursuant to section 1401 on income earned in the form of                       
          nonemployee compensation; and                                                  
               (3) whether petitioner is liable for the section 6651(a)(1)               
          addition to tax for failure to timely file income tax returns for              
          the taxable years 1992 through 1996.                                           





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