- 2 - Held, further, a penalty under sec. 6673, I.R.C., is due from P and is awarded to the United States in the amount of $5,000 Alan D. Stang, pro se. Stephen S. Ash, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: Respondent determined the following deficiencies and additions to tax with respect to petitioner’s Federal income taxes for the taxable years 1999 through 2001:1 Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1999 $3,596 $899.00 $174.01 2000 15,137 3,784.25 808.54 2001 7,501 1,875.25 299.77 The issues for decision in these consolidated cases are: 1) Whether petitioner received unreported income in the form of wages and nonemployee compensation from The Gem City Engineering Company (GCE) during 1999, 2000, and 2001, upon which he is liable for Federal income taxes; (2) whether petitioner is liable for self-employment taxes pursuant to section 1401 on income earned in the form of nonemployee compensation during 2000 and 2001; 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.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