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Background
Petitioner failed to file Federal income tax returns for the
taxable years 1990 through 1996. The record shows that
respondent prepared substitutes for return for petitioner’s
taxable years 1990 through 1996.
On September 21, 1999, respondent issued a notice of
deficiency to petitioner determining deficiencies in and
additions to his Federal income taxes for 1990 through 1996, as
follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1990 $8,855 $2,213.75 $579.77
1991 1,166 291.50 66.63
1992 559 139.75 24.36
1993 1,800 450.00 75.43
1994 9,154 2,288.50 475.00
1995 11,814 2,953.50 640.60
1996 544 136.00 28.96
The deficiencies were based principally on respondent’s
determination that petitioner failed to report various amounts of
nonemployee compensation as reported to respondent by third-party
payors on Forms 1099.
Petitioner has admitted that he received the September 21,
1999, notice of deficiency. However, petitioner did not file a
petition for redetermination with the Court challenging the
notice of deficiency.
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Last modified: May 25, 2011