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