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Respondent concedes that petitioner is not liable for the
addition to tax under section 6651(a)(2) for failure to pay for
the years in issue.1
After respondent’s concession, the issues for decision are:
1. Whether petitioner had unreported income as determined
by respondent for 1998-2001. We hold that he did.
2. Whether petitioner is liable for self-employment tax on
his earnings from Eniva Corp. of $221 for 2000 and $112 for 2001.
We hold that he is.
3. Whether petitioner’s filing status for 1998-2001 is
single. We hold that it is.
4. Whether petitioner may claim more than one personal
exemption for 1998-2001. We hold that he may not.
5. Whether petitioner is liable for the additions to tax
under section 6651(a)(1) for failure to file and section 6654 for
failure to pay estimated tax for 1998-2001. We hold that he is.
Section references are to the Internal Revenue Code in
effect for the taxable years in issue. Rule references are to
the Tax Court Rules of Practice and Procedure.
1 Respondent does not contend that petitioner is liable for
the addition to tax for failure to file under sec. 6651(a)(1) in
an amount larger than respondent determined for any of the years
in issue.
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Last modified: May 25, 2011