David Furniss - Page 2




                                        - 2 -                                         
                                        Addition to tax   Addition to tax             
           Taxable Year  Deficiency     Sec. 6651(a)(1)      Sec. 6654                
               1990      $5,917          $1,479             $387                      
               1994      4,425             939              191                       
               1996      4,093           1,023              218                       
               After concessions,2 the only remaining issues for decision             
          are:3  (1) Whether petitioner received unreported income during             
          1990, 1994, and 1996 of $25,838, $30,243, and $29,812,                      
          respectively; (2) whether petitioner is liable for additions to             
          tax for failure to file Federal income tax returns for 1990,                
          1994, and 1996; and (3) whether petitioner is liable for                    
          additions to tax for failure to make sufficient estimated tax               
          payments in 1990, 1994, and 1996.                                           
               Some of the facts have been stipulated, and the stipulations           
          are incorporated herein by this reference.  Petitioner resided in           
          Lawton, Oklahoma, at the time the petition was filed.                       
               During 1990, petitioner received commissions of $17,516, a             
          pension of $3,433, unemployment compensation of $4,065, dividends           
          of $20, and wages of $804.  During 1994, petitioner received                
          unemployment compensation of $2,450, dividends of $46, and wages            
          of $27,747.  During 1996, petitioner received a pension of                  


               2Petitioner did not dispute, nor did he present evidence               
          regarding, respondent’s determination that petitioner had self-             
          employment income in 1990 of $17,516 and was liable for self-               
          employment tax on that income.  This adjustment is deemed                   
          conceded in accordance with Rule 34(b)(4).                                  
               3The only other issues raised in the notices of deficiency             
          are computational.                                                          





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