- 3 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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