Todd B. Guthrie - Page 2

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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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