T.C. Memo. 2005-154
UNITED STATES TAX COURT
ALAN D. STANG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 6371-03, 19150-03. Filed June 27, 2005.
R determined deficiencies and additions to tax for
P’s 1999, 2000, and 2001 taxable years.
Held: P received unreported income in the form of
wages and nonemployee compensation during 1999, 2000,
and 2001, upon which he is liable for Federal income
taxes.
Held, further, P is liable for self-employment
taxes pursuant to sec. 1401, I.R.C., on income earned
in the form of nonemployee compensation during 2000 and
2001.
Held, further, P is liable for the sec.
6651(a)(1), I.R.C., addition to tax for failure timely
to file income tax returns for each of the years in
issue.
Held, further, P is liable for the sec. 6654,
I.R.C., addition to tax for failure to pay estimated
tax for the years 1999 through 2001.
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