- 2 -
decision to be entered is not reviewable by any other court, and
this opinion should not be cited as authority.
On July 10, 2001, respondent issued to petitioner a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 for unpaid 1992 Federal income tax and related
liabilities in the amount of $10,132.48. The issue for decision
is whether petitioner is liable for the Federal income tax
liability reported on his untimely 1992 Federal income tax
return. The resolution of this issue depends upon whether
certain income reported on petitioner’s 1992 return is includable
in petitioner’s income for that year.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Memphis,
Tennessee.
Petitioner was one of three incorporators of W.H.Y.
Construction Company, Inc. (W.H.Y. or WHY), incorporated in
Tennessee on May 12, 1989. W.H.Y. was administratively dissolved
by the Secretary of State of Tennessee on February 15, 1991,
because the corporation failed to file a report required by
Chapter 16 of the Tennessee Business Corporation Act. While in
existence, W.H.Y. was involved in residential construction and
renovations.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011