William M. Leggett - Page 2

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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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