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Held, further, petitioner is liable for the sec.
6654, I.R.C., addition to tax for failure to pay
estimated tax for each of the 6 years under
consideration.
Bruce David Cohen, pro se.
Miles D. Friedman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined the following
deficiencies and additions to tax with respect to petitioner’s
Federal income taxes:
Taxable Income Tax Additions To Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1986 $94,940 $23,735 $4,594
1988 58,089 14,522 3,737
1989 70,535 17,634 4,770
1990 119,550 29,887 7,827
1991 70,516 17,629 4,030
1992 78,024 19,506 3,403
After concessions, the issues remaining for decision are:
(1) Whether petitioner’s sole proprietorship earned net
income in the amounts asserted by respondent for each of the 6
years involved in this case;
(2) whether petitioner recognized capital gain from the sale
of stock in 1989 and 1990 in the amounts asserted by respondent;
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