- 4 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011