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After concessions,2 we must decide the following issues:
1. Whether we have jurisdiction to decide whether
petitioner’s 1993 tax liabilities were discharged in his 1999
bankruptcy proceeding. We hold that we do not. Neilson v.
Commissioner, 94 T.C. 1, 8-9 (1990).
2. Whether petitioner may deduct taxes and wages in amounts
greater than respondent allowed. We hold that he may not.
3. Whether petitioner is liable for self-employment tax on
income that he received from his business in 1993. We hold that
he is.
4. Whether petitioner recognized $5,369 of capital gain
income from the sale of stock in 1993. We hold that he did.
5. Whether petitioner is liable for the addition to tax
under section 6651(a)(1) for failure to timely file his 1993
return. We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Hurricane, West Virginia, when he filed
the petition in this case. He was married in 1993 and divorced
in 1995.
2 Respondent concedes that petitioner is entitled to a
dependency exemption for his spouse and that disability insurance
proceeds are not taxable income.
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