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(4) Is petitioner liable for an addition to tax under
section 6651(a)(1) for each of the years at issue? We hold that
he is.
(5) Is petitioner liable for an addition to tax under
section 6654(a) for each of the years at issue? We hold that he
is.
FINDINGS OF FACT
Most of the facts have been deemed established pursuant to
Rule 90(c) and pursuant to the Court’s Order under Rule 91(f)
dated May 8, 2003.
At the time he filed the petition in this case, petitioner’s
mailing address was in Excelsior, Minnesota.
Beginning in 1990 and continuing throughout each of the
years at issue, petitioner operated a sole proprietorship under
the name Native Skies. (We shall refer to petitioner’s sole
proprietorship Native Skies as petitioner’s sole proprietorship.)
At all relevant times, including during each of the years at
issue, petitioner’s sole proprietorship was engaged in the
business of selling jewelry and certain other items, such as
rugs.
On April 6, 1994, the Secretary of State of Minnesota
(Secretary of State) issued a certificate of incorporation to a
corporation identified in that certificate as “Native Skies Inc.”
During the years at issue, Native Skies, Inc., was inactive.
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