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petitioner’s net earnings from his law practice are subject to
self-employment taxes and whether payment of those taxes is
voluntary. At the time the petition in this case was filed,
petitioner resided in Knoxville, Tennessee.
Petitioner did not file timely a Form 1040, U.S. Individual
Income Tax Return, for taxable years 1995 and 1996. On December
22, 1998, respondent issued a notice of deficiency in which he
determined the following deficiencies and additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1995 $68,735 $17,183.75 $3,727.01
1996 12,245 3,061.25 651.74
Some of the deficiencies were attributable to petitioner’s
failure to report or otherwise pay self-employment taxes.
On March 23, 1999, petitioner filed a timely petition to
this Court. On July 7, 2000, petitioner executed Federal income
tax returns for taxable years 1995 and 1996. On the Schedules C,
Profit or Loss from Business, attached to those returns,
petitioner reported net income of $116,814 for taxable year 1995
and $41,111 for taxable year 1996. The Schedules C showed that
the income was derived from Mr. Baker’s business or profession as
an “Attorney”. On the Schedules SE, Self-Employment Tax,
1(...continued)
Practice and Procedure.
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