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petitioner is liable for tax relating to unreported income and
for the section 6651(a)(1)1 and 6654(a) additions to tax.
FINDINGS OF FACT
Petitioner is a licensed orthopedic physician. During 2002,
petitioner rendered services to Park Ridge Orthopedics, P.A., a
professional medical corporation, in exchange for $255,769.
Mountain Health Care, P.A., also paid petitioner $54,950 for his
medical services. In addition, petitioner received $79,100 of
rent, $3,601 of interest, and $150 of dividends.
Petitioner did not file a tax return or pay estimated taxes
relating to 2002. As a result, respondent issued a notice of
deficiency on April 5, 2005. Respondent determined that
petitioner was liable for a $127,490 deficiency in income tax, a
$28,685 section 6651(a)(1) addition to tax for failure to file a
return, a $13,386 section 6651(a)(2) addition to tax for failure
to timely pay, and a $4,260 section 6654(a) addition to tax for
failure to pay estimated taxes.
On July 1, 2005, petitioner, while residing in Reno, Nevada,
filed his petition. At trial, on January 30, 2006, respondent
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011