- 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.
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Last modified: May 25, 2011