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Year Deficiency Sec. 6651(a) Sec. 6654
1992 $3,011 $742 $129
1993 3,807 952 159
1994 5,783 1,446 298
1995 5,496 1,359 296
1996 5,817 1,453 309
All section references are to the Internal Revenue Code in effect
for the years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
After concessions, the remaining issues for decision are
whether petitioner is liable for: (1) Income and self-employment
taxes relating to reconstructed self-employment income and (2)
additions to tax.
FINDINGS OF FACT
Petitioner resided in Dallas, Texas, at the time his
petition was filed. During the years in issue, petitioner worked
in both permanent and temporary positions for various businesses.
Petitioner received $25,968, $21,103, $7,398, $10,936, and $5,529
of wages, interest income, and unemployment compensation relating
to 1992, 1993, 1994, 1995, and 1996, respectively. Petitioner
did not file tax returns for any of the years in issue.
On July 24, 1996, petitioner submitted a Pre-Employment
Questionnaire (questionnaire) to Jakes’ Temps. On the
questionnaire, petitioner listed several previous employers.
Petitioner stated that he worked for Pro Staff during 1995 and
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