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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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