T.C. Memo. 2004-234
UNITED STATES TAX COURT
GREG OLSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21529-03. Filed October 13, 2004.
Respondent determined deficiencies and additions
to tax for petitioner’s 1999 and 2000 taxable years.
Held: Petitioner received taxable income during
1999 and 2000, and a portion thereof is subject to
self-employment tax. Sec. 861, I.R.C., and regulations
thereunder, do not exempt his compensation from tax.
Held, further, petitioner is liable for the sec.
6651(a)(1), I.R.C., addition to tax for failure timely
to file income tax returns for each of the years in
issue.
Held, further, petitioner is liable for the sec.
6654, I.R.C., addition to tax for failure to pay
estimated tax for the year 2000.
Greg Olson, pro se.
Cameron M. McKesson, for respondent.
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