Robert D. Hill - Page 2

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          We decide as to that year:                                                  
               1.  Whether petitioner failed to include in his gross income           
          self-employment income of $106,077 and a tax refund of $266.  We            
          hold he did.                                                                
               2.  Whether petitioner is liable for self-employment tax on            
          his self-employment income.  We hold he is.                                 
               3.  Whether petitioner is liable for the addition to tax and           
          the accuracy-related penalty.  We hold he is.                               
               4.  Whether we shall impose a penalty on petitioner under              
          section 6673 for advancing frivolous and/or groundless claims.              
          We shall impose a penalty of $15,000.                                       
               Section references are to the applicable versions of the               
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
                                  FINDINGS OF FACT                                    
               Some facts were stipulated.  The stipulated facts and the              
          exhibits submitted therewith are incorporated herein by this                
          reference.  We find the stipulated facts accordingly.  Petitioner           
          resided in Sedona, Arizona, when he petitioned the Court.                   
               During 1999, petitioner was a self-employed salesperson for            
          London Bridge Resort LLC (LLC).  In that capacity, he solicited             
          individuals and entities to purchase timeshare interests in the             
          London Bridge Resort Time Share Condominium.  LLC generally                 
          compensated petitioner for his services by paying to him                    




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