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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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