Brett Alan Combs - Page 3

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               Respondent determined for 2000 a deficiency in petitioner’s            
          Federal income tax of $8,698, an addition to tax under section              
          6651(a)(1) of $1,957.05, an addition to tax under section                   
          6651(a)(2) of $1,652.62, and an addition to tax under section               
          6654(a) of $467.81.                                                         
               The issues for decision are whether petitioner:  (1) Had               
          unreported income, (2) is liable for self-employment tax, (3) is            
          liable for the addition to tax under section 6651(a)(1) for                 
          failure to file timely his Federal income tax return without                
          reasonable cause, (4) is liable for the addition to tax under               
          section 6651(a)(2) for failure to pay timely the tax due without            
          reasonable cause, and (5) is liable for the addition to tax under           
          section 6654(a) for failure to pay estimated income tax.                    
                                     Background                                       
               The stipulated facts and exhibits received into evidence are           
          incorporated herein by reference.  At the time the petition in              
          this case was filed, petitioner resided in Fort Lauderdale,                 
          Florida.                                                                    
               Petitioner failed to file an income tax return for 2000, and           
          the Internal Revenue Service made a return for him under section            
          6020(b).  Petitioner received in 2000, nonemployee compensation             
          of $34,673, dividends of $22 and capital gain of $261.                      
          Petitioner does not contest the amounts or character of the items           
          that respondent determined that he received in 2000.  Respondent            
          determined that petitioner is allowed a personal exemption, the             




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