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Petitioner Virginia L. Dimon
Additions to Tax Under
Year Deficiency Sec. 6651(a)(1)1 Sec. 6654
1996 $11,773 $2,919.75 $626.61
Petitioner Charles F. Dimon
Additions to Tax Under
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1996 $43,776 $10,944 $2,329.98
The issues remaining for decision2 are:
(1) Did Mr. Dimon receive $127,970 of nonemployee compensa-
tion during 1996? We hold that he did.
(2) Is Mr. Dimon entitled to deduct for 1996 the Schedule C
expenses that he is claiming? We hold that he is not.
(3) Is each petitioner liable for 1996 for the addition to
tax under section 6651(a)(1)? We hold that each petitioner is so
liable.
(4) Is each petitioner liable for 1996 for the addition to
tax under section 6654? We hold that each petitioner is so
liable.
1All section references are to the Internal Revenue Code
(Code) in effect for the year at issue. All Rule references are
to the Tax Court Rules of Practice and Procedure.
2Computational or correlative issues also remain, resolution
of which flows automatically from our resolution of the determi-
nations in the notice of deficiency (notice) issued to petitioner
Virginia L. Dimon (Ms. Dimon) and in the notice issued to peti-
tioner Charles F. Dimon (Mr. Dimon), which we address herein.
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