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(3) whether petitioner is liable for the section 6651(a)(1)
addition to tax for failure timely to file an income tax return
for 1993; and
(4) whether petitioner is liable for the section 6662(a)
accuracy-related penalty for 1993.
Additional adjustments to petitioner's self-employment taxes
and deduction for self-employment taxes are computational in
nature and will be resolved by our holdings on the foregoing
issues.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
I. General Background
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At trial, the parties
stipulated that, to the extent relevant, the facts contained in
Hastings v. Commissioner, T.C. Memo. 1999-167, may be
incorporated by reference in this proceeding. Where relevant,
the findings of fact in Hastings are incorporated herein by this
reference. At the time the petition was filed in this case,
petitioner resided in Julian, California.
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