- 4 -
and $52,871 in 2002 as an agent for Bankers United.4 In
addition, respondent asserted four other insurance companies
reported petitioner was paid total commissions of $15,362 in
2002.5
Petitioner failed to file Federal income tax returns and
failed to pay Federal income taxes for the years at issue. Using
third-party information returns, on April 21, 2004, respondent
issued separate notices of deficiency to petitioner for the years
at issue, setting forth unreported income of $113,469 and
$68,233, respectively, together with Federal income tax
liabilities of $39,799 and $21,789, respectively, as well as
additions to tax under section 6651(a)(1) of $9,949 and $5,447,
and additions to tax under section 6654(a) of $1,590 and $728,
respectively.
Petitioner timely filed petitions regarding his 2001 and
2002 deficiencies on July 15 and July 19, 2004, respectively.
These cases were consolidated on February 11, 2005, for briefing,
trial, and opinion. Trial was held on this matter on March 17,
4 The commissions for 2001 were reflected by Bankers United
as follows: $70,304.52 (agent No. 58AG93 earnings) + $192.88
(agent No. 58AG93 renewals) + $26,882.90 (agent No. 58V384
earnings) + $16,088.89 (agent No. 58V384 renewals) = $113,469.19
5 The Form 4549, Income Tax Examination Changes, for 2002
reflected that petitioner received commissions of $1,826 from New
York Life Insurance Co., $6,414 from John Hancock Life Insurance
Co., $4,829 from GE Capital Insurance, and $2,293 from
Continental Casualty Co.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011