Bruce David Cohen - Page 3




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               (3) whether petitioner’s filing status was single or married           
          filing separate in 1992;                                                    
               (4) whether petitioner is entitled to only the standard                
          deduction or, instead, to itemized deductions, in 1990;                     
               (5) whether petitioner is liable for the section 6651(a)(1)            
          addition to tax for failure timely to file income tax returns for           
          each of the 6 years at issue; and                                           
               (6) whether petitioner is liable for the section 6654                  
          addition to tax for failure to pay estimated tax for each of the            
          6 years involved.                                                           
               Additional adjustments to petitioner’s self-employment taxes           
          and deduction for self-employment taxes are computational in                
          nature and will be resolved by our holdings on the foregoing                
          issues.                                                                     
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the years at            
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
               To facilitate disposition of the foregoing issues, we shall            
          first make general findings of fact and then combine our findings           
          and opinion with respect to each issue.                                     
          I.  General Findings of Fact                                                
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            






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Last modified: May 25, 2011