Keith M. Rudman - Page 2




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                                       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 traded               








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