- 5 - 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 expensesPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011