Thomas Y. Wallace - Page 2




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               The issues for consideration are: (1) Whether petitioner               
          failed to report taxable income for taxable years 1988 and 1989,            
          as determined by respondent using the net worth method of income            
          reconstruction; (2) whether petitioner is liable for an addition            
          to tax for fraudulent failure to file a Federal income tax return           
          pursuant to section 6651(f) for taxable year 1989; (3) whether              
          petitioner is liable for an addition to tax for negligence                  
          pursuant to section 6653(a)(1) for taxable year 1988; (4) whether           
          petitioner is liable for an addition to tax for failure to file a           
          Federal income tax return pursuant to section 6651(a)(1) for                
          taxable year 1988; (5) whether petitioner is liable for self-               
          employment tax pursuant to section 1401 for taxable years 1988              
          and 1989; and (6) whether petitioner is liable for additions to             
          tax for failure to pay estimated income tax pursuant to section             
          6654 for taxable years 1988 and 1989.1                                      
                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, which are               
          herein incorporated by this reference.  When he petitioned the              
          Court, petitioner resided in Cherokee, Alabama.                             
               On November 25, 1987, petitioner purchased an 80-acre farm             
          (the Carskadon farm) in Clark County, Missouri, for $45,000.  A             


               1 Unless 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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