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Addition to Tax
Year Deficiency Sec. 6651(f)
1990 $18,735 $17,351
1991 15,722 17,194
1992 20,987 22,989
1993 19,183 19,981
1994 34,675 31,387
The issues for decision are: (1) Whether petitioner
underreported gross receipts from his dental practice for taxable
years 1990 through 1994 as determined by respondent; (2) whether
for taxable years 1990, 1991, 1993, and 1994, petitioner
substantiated his claimed wage expense deductions; and (3)
whether for each year in issue, petitioner is liable for the
section 6651(f) addition to tax for fraudulent failure to file an
income tax return.1
FINDINGS OF FACT
The parties have stipulated some of the facts, which we
incorporate herein by this reference. When he petitioned the
Court, petitioner resided in Abingdon, Virginia.
Petitioner’s Dental Practice
From 1985 through the years in issue, petitioner was sole
proprietor of his general dental practice in Abingdon, Virginia
(the dental practice). The town of Abingdon, Virginia
(Abingdon), required petitioner to file, on or before January 31
each year, a business license application (the application)
1 All section references are to the Internal Revenue Code in
effect for the relevant taxable years. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011