- 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