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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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