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(9) whether petitioner had unreported income in 1993 of
$310 from Taxman’s payment for a repair of petitioner’s wife’s
car, $7,000 from WFIC’s payment to petitioner’s sister, $28,660
from WFIC’s purchase of a car, and $3,000 in cash taken from
Taxman. We hold that petitioner had unreported income of $310
from Taxman’s payment for a repair of petitioner’s wife’s car,
$7,000 from WFIC’s payment to petitioner’s sister, $18,660 from
WFIC’s purchase of a car, and $3,000 in cash taken from Taxman;
(10) whether petitioner is entitled to claim head-of-
household filing status in 1990. We hold that he is not;
(11) whether petitioner is liable for self-employment tax
on his unreported crop hail insurance commission in 1990 and real
estate commission in 1992. We hold that he is; and
(12) whether the understatement in each of 1990, 1991,
1992, and 1993 is subject to the fraud penalty under section
6663(a). We hold that petitioner is liable for the fraud penalty
under section 6663(a) with respect to unreported income of $3,000
in each year.
FINDINGS OF FACT
Some of the facts are stipulated. The stipulations of fact
and the attached exhibits are incorporated herein by this
reference. At the time the petition was filed, petitioner
resided in Fargo, North Dakota.
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