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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1999 $ 7,921 $1,980 $ 12
2000 25,179 6,294 1,344
2001 13,601 3,400 543
2002 11,571 2,892 386
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The primary issues for decision are the amount of
petitioner’s 1999, 2000, 2001, and 2002 income, whether
petitioner is liable for self-employment taxes on the income, and
whether petitioner is liable for the additions to tax determined
by respondent.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Wayzata, Minnesota.
In 1999, petitioner applied for and received a commercial
driver’s license. Shortly thereafter, petitioner answered an
advertisement placed by Edina Couriers, Inc. (ECI), for truck
drivers.
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Last modified: March 27, 2008