Stuart M. Smith, Jr. - Page 2




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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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