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The issues to be decided are: (1) Whether petitioner failed
to report $78,491 in 1997 as income for Federal income tax
purposes; (2) whether petitioner failed to substantiate his
claimed Schedule C, Profit or Loss From Business, expenses for
1998, 1999, 2000, and 2001; (3) whether petitioner is liable for
additions to tax under section 6651(a)(1) for all years at issue;
and (4) whether petitioner is liable for accuracy-related
penalties under section 6662 for 1998, 1999, 2000, and 2001.1
FINDINGS OF FACT
Petitioner resided in Glendora, California, at the time the
petitions were filed.
During the years at issue, petitioner was employed by
various companies as a systems engineer. The work he performed
as a systems engineer was done out of his home. In addition, he
started his own company in 1998 called Connect4Less. In this
capacity, he repaired computers, programmed computers, and
developed Web sites for individuals. Petitioner also operated
Connect4Less out of his home.
Petitioner did not file a Federal income tax return for
1997. He did not make estimated tax payments for 1997.
Petitioner did not file his 1998, 1999, 2000, and 2001 Federal
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended. All Rule references are
to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated. Amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011