Daniel E. Spurlock - Page 2

                                        - 2 -                                         
                                         Additions to Tax                             
          Tax                      Sec.           Sec.          Sec.                  
          Year   Deficiency       6651(a)(1)     6651(a)(2)       6654                
          1994     $9,759         $1,123.25       --        $202.78                   
          1995     15,074          2,313.25       --        466.64                    
          1996     16,418          2,474.33   To be determined   553.26               
          1997     19,555          3,108.83   To be determined   705.14               
          1998     10,778          1,149.75   To be determined   204.99               
          By amended answer, respondent asserted increased deficiencies               
          attributable to nonemployee compensation that petitioner                    
          allegedly received from The Louisville Chorus, Inc. (Louisville             
          Chorus), in amounts of $24,000 and $22,400 in 1995 and 1996,                
          respectively, and associated additions to tax pursuant to                   
          sections 6651(a)(1) and 6654.                                               
               The issues for decision are:  (1) Whether petitioner is                
          liable for deficiencies as determined in the notice of                      
          deficiency, (2) whether petitioner is liable for increases in               
          deficiencies as alleged in respondent’s amended answer, (3)                 
          whether petitioner is liable for additions to tax under sections            
          6651(a)(1) and 6654(a) for each year at issue,2 and (4) whether             
          we should grant respondent’s motion to impose sanctions pursuant            
          to section 6673(a).                                                         
                                     Background                                       
               The parties have stipulated some facts, which we incorporate           
          herein by this reference.  When he petitioned this Court,                   
          petitioner resided in Louisville, Kentucky.                                 


               2 Respondent concedes the determinations under sec.                    
          6651(a)(2).                                                                 



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