-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 him
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011