Gregory Dean Owens - Page 2




                                        - 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.                           




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