- 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