Michael J. Roberts - Page 3




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             Taxable        Income Tax              Additions to Tax                   
              Year          Deficiency      Sec. 6651(a)(1)     Sec. 6654              
              1989          $8,964.00          $2,241.00         $604.00               
              1990          7,867.00           1,966.75          516.00                
              1991          8,190.00           2,047.50          470.00                
          Respondent’s determinations were based in large part upon Forms              
          1099 filed by various third-party payors, which forms respondent             
          alleges indicated that petitioner operated a drywall installation            
          business.  Respondent also determined that petitioner received               
          additional income for each year not reported on Forms 1099                   
          through application of tables produced by the U.S. Department of             
          Labor, Bureau of Labor Statistics.  These adjustments were                   
          explained in the notice as follows:                                          
                    Based on statistical information from the U.S.                     
               Department of Labor, we have established amounts of                     
               personal living expenses and amounts of income needed                   
               to pay for those expenses.  Since your income was not                   
               sufficient to pay for all of your personal living                       
               expenses, we have adjusted your income accordingly.                     
               Petitioner thereafter on July 29, 1994, filed delinquent                
          Forms 1040 for 1989 through 1991.  These returns each reflected              
          the same Newport Beach address to which the notice of deficiency             
          had been sent and included a Schedule C, Profit or Loss From                 
          Business, for “Drywall Installation”, “DRYWALL INSTALLER”, or                
          “DRYWALL CONTRACTOR”.  The Forms 1040 and Schedules C showed                 
          gross receipts, interest, and a State income tax refund in                   
          amounts identical to those shown in the Forms 1099 received by               






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