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After concessions,1 the issues for decision are: (1)
Whether petitioner had unreported income from veterinary
services, the sale of animals, and oil and gas royalties in the
years in issue; (2) whether petitioner is liable for additions to
tax for fraud under sections 6653(b)(1)2 and 6651(f); (3) whether
petitioner is liable for failure to pay estimated tax under
section 6654(a); and (4) whether petitioner is liable for the
imposition of a penalty under section 6673 for taking a frivolous
and groundless position in these proceedings.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in
Bristolville, Ohio.
1Respondent concedes the following amounts of income set
forth in the computation of petitioner’s gross receipts from
veterinary services and the sale of animals in the statutory
notice of deficiency: $34,450 in 1988 (see appendix A); $1,815
in 1989 (see appendix B); $1,800 in 1990 (see appendix C);
$10,500 in 1991 (see appendix D); and $391 in 1992 (see appendix
E).
2Unless otherwise indicated, 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.
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