Richard P. Kringen - Page 6




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          earnings from self-employment subject to the tax imposed on such            
          income pursuant to section 1401.                                            
               Petitioner’s 1990 taxable income was computed by allowing a            
          personal exemption deduction, a deduction attributable to the               
          imposition of the self-employment tax, and the standard deduction           
          applicable to a single individual.  For all other years in issue,           
          petitioner’s taxable income was computed by allowing a personal             
          exemption deduction, a deduction attributable to the imposition             
          of the self-employment tax, and itemized deductions.  Respondent            
          further imposed additions to tax under sections 6651(a)(1)                  
          (failure to file returns timely) and 6654(a) (underpayment of               
          estimated tax) for all the years in issue, and under section                
          6651(a)(2) (failure to pay taxes timely) for the years 1996,                
          1997, and 1998.                                                             
          Discussion                                                                  
               In the petition, petitioner alleged that respondent erred in           
          the determinations made for each year because each determination            
          was based “on no facts”.  At trial, however, petitioner did not             
          dispute the amount of gross income attributed to him for each               
          year in the notice of deficiency.  He testified that those                  
          amounts “would probably be close to what I earned” and, to the              
          extent that the income represented “gross salaries”, the amounts            
          “would probably be correct”.  Instead, he claimed that he should            
          have been allowed deductions for trade or business expenses                 






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