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Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 66541
1993 $12,253 $9,189.75 $513.41
1994 6,698 5,023.50 347.56
1995 5,554 4,165.50 301.16
1996 3,256 2,442.00 173.32
1997 5,269 3,951.75 281.90
1998 4,431 3,323.25 202.76
1 The notice of deficiency cites sec. 6653 as the basis for
the addition to tax, but respondent’s answer clarified that sec.
6654 is the correct basis for this addition to tax.
After concessions,1 the remaining issues for decision are
(1) whether petitioner’s asserted vow of poverty causes him to be
exempt from liability for Federal income taxes, including self-
employment tax, for taxable years 1993, 1994, 1995, 1996, 1997,
and 1998; and (2) whether the doctrine of collateral estoppel
limits the aggregate amount of petitioner’s tax deficiencies and
additions to tax due for 1994, 1995, 1996, and 1997 to the amount
of restitution ordered at petitioner’s prior criminal proceeding.
We hold that petitioner is liable for income taxes, and the
doctrine of collateral estoppel is not applicable.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years in issue,
1Petitioner concedes that he operated Imperial
Communications, Inc., as a sole proprietorship, and that he was
remunerated in 1993, 1994, 1995, 1996, 1997, and 1998 in
connection with services he provided. Petitioner also concedes
that if the deficiencies are sustained, he is liable for the
additions to tax as determined in the notice of deficiency.
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Last modified: May 25, 2011