- 2 -
under section 6651(a).1 The issues remaining for our
consideration are: (1) Whether petitioner failed to report
income in the amounts of $75,614 and $27,462 for 1992 and 1993,
respectively; (2) whether petitioner has shown entitlement to
business deductions in excess of those allowed by respondent; and
(3) whether petitioner is liable for self-employment taxes.
FINDINGS OF FACT
At the time his petition was filed, petitioner’s legal
residence was in the State of Colorado. Brenda Benz was
petitioner’s intimate and confidant, and she followed
petitioner’s direction in business matters and was remunerated
for her efforts. Gary Krubsack was a friend of petitioner’s and
participated in petitioner’s business activities. During 1992 and
1993, petitioner identified corporations that were not current
with their obligations to the State of Colorado and that held
title to real estate or other property. When petitioner
discovered that a corporation was not properly registered and
therefore in a delinquent inactive status with the State of
Colorado, he organized a new corporation with the same name as
the delinquent corporation and caused the transfer of the title
of properties held by the delinquent corporation to a third
1 Section references are to the Internal Revenue Code in
effect for the period under consideration. Rule references are
to the Tax Court’s Rules of Practice and Procedure. Respondent
conceded that petitioner is not liable for the addition to tax
under sec. 6651(a) for either taxable year.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011