- 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
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