William R.Tinnerman - Page 2

                                        - 2 -                                         
          Year       Deficiency 6651(a)(1) 6651(a)(2)  6651(f)    6654(a)             
          1999       $75,888    -          $18,972    $55,018.80 $3,672.67            
          2000       69,302     -               2     51,976.50  3,701.75             
          2001       52,823     -               3     39,617.25  2,111                
          2002       44,220     $11,055    -          -          1,477.71             


          The issues we must decide are: (1) Whether the record in the                
          instant case should be reopened to receive new evidence; (2)                
          whether petitioner has a zero basis in his S corporation stock;             
          (3) whether petitioner is liable for deficiencies in income tax             
          for taxable years 1999 through 2002; (4) whether petitioner is              
          liable for the fraud penalty pursuant to section 6651(f)4 for               
          taxable years 1999, 2000, and 2001; (5) whether petitioner is               
          liable for an addition to tax pursuant to section 6651(a)(1) for            
          failure to file his 2002 tax return; (6) whether petitioner is              
          liable for an addition to tax pursuant to section 6654(a) for               
          failure to make estimated payments for tax years 1999 through               
          2002; and (7) whether petitioner is liable for a penalty pursuant           
          to section 6673.                                                            




               2To be calculated.                                                     
               3To be calculated.                                                     
               4Unless otherwise indicated, all Rule references are to the            
          Tax Court Rules of Practice and Procedure, and all section                  
          references are to the Internal Revenue Code in effect for the               
          years in issue.                                                             




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