William Richard Baker, Jr. - Page 2




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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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