- 2 - 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 andPage: Previous 1 2 3 4 5 Next
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