Gary Don Erwin - Page 3

                                          2                                           
               Respondent issued petitioner a notice of deficiency in the             
          amount of $4,167 for taxable year 2001.  In the same notice,                
          respondent determined the following additions to tax:                       
               Sec. 6651(a)(1)     Sec. 6651(a)(2)     Sec. 6654(a)(2)                
                                                                                     
               $937                     $562                $164                      
               After concessions,1 the sole issues for decision are whether           
          petitioner is liable for additions to tax under sections                    
          6651(a)(1) and 6654(a).  We hold that he is.                                
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by reference.                                           
               At the time the underlying petition was filed, petitioner              
          resided in Clifton, Texas.                                                  
               During the taxable year at issue, 2001, and the previous               
          taxable year, 2000, petitioner worked as a corporate trainer for            
          Compliance Systems, Inc. (Compliance).  Under the terms of his              
          employment, Compliance provided petitioner with materials                   
          necessary for him to lead hazardous materials training courses              
          for its employees.                                                          
               A dispute arose between petitioner and Compliance sometime             
          in late 2001 regarding petitioner’s employment status.  Although            


          1 Respondent has conceded the addition to tax under sec.                    
          6651(a)(2) for failure to pay.  Petitioner conceded that he                 
          received wages of $17,588 and interest income of $11.                       




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