Randal W. Howard - Page 2




                                        - 2 -                                         


                                       Additions to tax                               
               Year    Deficiency     Sec. 6651(a)(1)  Sec. 6654                      
               1993     1$3,136          2$784.00          --                         
               1994         4,162  775.75       $154.91                               
               1995        10,146  2,254.50        482.15                             
               1Respondent asserts that the deficiency be increased to $5,832         
          in the Amended Answer because the original deficiency determination         
          gave petitioner credit for a prior erroneous assessment.                    
               2Respondent asserts that the addition to tax be increased to           
          $1,458 in the Amended Answer because the original deficiency                
          determination gave petitioner credit for a prior erroneous                  
          assessment.                                                                 
               After concessions, the issues for decision are:  (1) Whether           
          petitioner received compensation for his labor; (2) whether                 
          payments made to petitioner for his labor should be included in             
          petitioner’s taxable income; (3) whether petitioner is liable for           
          additions to tax for failing to timely file Federal income tax              
          returns and for failing to pay estimated taxes; and (4) whether a           
          penalty should be awarded to the United States under section                
          6673.1                                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and supplemental stipulation of facts              
          are incorporated herein by this reference.  Petitioner resided in           
          Tucson, Arizona, at the time he filed his petition.                         



               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code applicable to the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011