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1989 and 1990 Federal income taxes. Petitioner also petitioned
the Court to redetermine respondent’s determinations as to his
1991, 1992, and 1993 Federal income taxes.
As to the respective years 1989 and 1990, respondent
determined that petitioners were liable for deficiencies of
$2,271 and $10,471, section 6651 additions to tax of $568 and
$2,618, and section 6662 accuracy-related penalties of $454 and
$2,094.1 As to the respective years 1991, 1992, and 1993,
respondent determined that petitioner was liable for deficiencies
of $7,739, $36,363, and $2,577, section 6651 additions to tax of
$1,935, $9,091, and $644, section 6654 additions to tax of zero,
$1,586, and $108, and section 6662 accuracy-related penalties of
$1,548, zero, and zero.
Following concessions and our dismissal of this case as to
Ms. Ihlenfeldt for failure to prosecute properly, we are left to
decide:2
1. Whether petitioner’s taxable income includes self-
employment income in the amounts determined by respondent. We
hold it does.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, Rule
references are to the Tax Court Rules of Practice and Procedure,
and dollar amounts are rounded.
2 Petitioner’s posttrial brief addresses only the two issues
set forth below. We hold that petitioner has conceded all other
issues raised by the pleadings which were not conceded by
respondent.
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