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petitioner’s 2001 Federal income tax. The issues for decision
are: (1) Whether income received by petitioner in 2001 is
taxable; (2) whether petitioner is liable for self-employment tax
for 2001; (3) whether petitioner is liable for an addition to tax
pursuant to section 6651(a)(1) for 2001; (4) whether petitioner
is liable for an addition to tax pursuant to section 6654(a) for
2001; and (5) whether to impose a penalty pursuant to section
6673.
FINDINGS OF FACT
Pursuant to Rule 91(f), some of the facts have been deemed
stipulated and are so found. The stipulation of facts and the
attached exhibits are incorporated herein by this reference. At
the time he filed the petition, petitioner resided in Florida.
Petitioner’s Prior Tax Court Case
In October 2001, petitioner participated in a trial before
this Court regarding his 1994, 1995, and 1996 tax years (2001
trial). The issues in the 2001 trial regarded unreported income
(deficiencies), delinquency additions to tax, and estimated tax
additions to tax for 1994, 1995, and 1996.
Petitioner did not dispute receiving the moneys listed in
the statutory notice of deficiency for 1994, 1995, and 1996; he
merely disputed that these amounts met the definition of income.
Before the 2001 trial, petitioner sent respondent a request
for admissions. Respondent responded to the request for
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