-2- 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 himPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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