- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011