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Sec. 1.6081-4(a)(4), Income Tax Regs. If the estimate of tax is
not reasonable, then the extension request, even if granted, will
be void. Clayton v. Commissioner, 102 T.C. 632, 651 (1994).
Ahmed did not introduce into evidence the allegedly filed
Form 4868, and we are therefore unable to determine whether Ahmed
reasonably estimated his 1998 tax liability. We infer from
Ahmed’s failure to introduce the allegedly filed Form 4868 that
the evidence would be detrimental to Ahmed. See Wichita Terminal
Elevator Co. v. Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162
F.2d 513 (10th Cir. 1947).
For purposes of computing Ahmed’s 1998 section 6651(f)
fraudulent failure to file addition to tax, Ahmed’s 1998 joint
Federal income tax return is to be treated as filed untimely.4
Self-Employment Taxes
Ahmed argues that for 1997 and 1998 self-employment taxes
should not be imposed on the stipulated collapsed income charged
to him from the nominee corporations.
Section 1401(a) imposes a self-employment tax on
individuals’ self-employment income. Self-employment income is
defined as the “net earnings from self-employment”, which is
4 Ahmed, in his Rule 155 computation, made several
alternative arguments relating to the length of the applicable
period for computing the sec. 6651(f) addition to tax. Ahmed’s
arguments are without merit, and Ahmed’s 1998 joint Federal
income tax return is to be treated as filed more than 5 months
past the due date.
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Last modified: May 25, 2011