James C. Blanning, Jr. - Page 2

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          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.                                 




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