- 2 - OPINION SWIFT, Judge: For 1994, respondent determined a deficiency in petitioner’s Federal income tax and an accuracy-related penalty as follows: Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1994 $312,026 $57,203 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the remaining issue for decision is whether petitioner, a commodities dealer, is subject to self- employment tax on earnings from trading U.S. Treasury bond commodities futures contracts. Background The facts of this case were submitted fully stipulated under Rule 122, and are so found. At the time the petition was filed, petitioner resided in Winnetka, Illinois. In years prior to 1994, petitioner was a member of the Chicago Board of Trade (CBOT), and petitioner actively tradedPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011