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The issues for decision are:
1. Whether petitioner is liable for income tax on amounts
that Terminex International Co., LP, paid to an unincorporated
business called King of Construction in 1994, 1995, and 1996. We
hold that he is.
2. Whether petitioner may deduct business expenses in
1994, 1995, and 1996. We hold that he may not because he has not
provided substantiation or any other convincing basis for us to
estimate the amount of the expenses.
3. Whether petitioner is liable for self-employment tax
for 1994, 1995, and 1996. We hold that he is.
4. Whether petitioner is liable for additions to tax for
failure to file a return and failure to pay estimated tax for
1994, 1995, and 1996 and failure to pay tax for 1996. We hold
that he is.
5. Whether petitioner is liable for a penalty under
section 6673. We hold that he is in the amount of $3,500.
Unless otherwise indicated, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
Some of the facts are stipulated and are so found.
Petitioner lived in Lebanon, Indiana, when he filed the petition.
Petitioner did business during the years in issue as King of
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