- 8 - Commissioner, 85 T.C. 731, 742-743 (1985). Thus, petitioner may not deduct any amount for business expenses in the years in issue. D. Whether Petitioner Is Liable for Self-Employment Tax Petitioner does not deny that he is liable for self- employment tax. However, he testified that King of Construction paid wages to him. If that were true, he would not be liable for self-employment tax. Petitioner testified that money from Terminex went into an account in the name of King of Construction. He paid business expenses from the account and kept what was left. We conclude that payments from Terminex are self-employment income to petitioner, and not wages. We conclude that petitioner is liable for self-employment tax in the years in issue. E. Whether Petitioner Is Liable for the Additions to Tax for Failure To File Returns for 1994, 1995, and 1996, for Failure To Pay Tax for 1996, and Failure To Pay Estimated Tax for 1994, 1995, and 1996 Petitioner contends in his petition that he is not liable for the additions to tax for failure to file timely returns and pay tax under section 6651(a)(1) or (2), or for failure to pay estimated tax under section 6654. Petitioner concedes that he did not file a tax return or pay any tax, including estimated tax, for 1994, 1995, or 1996. He offered no evidence as to why he failed to do so. We conclude that petitioner is liable forPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011