Ronald E. Byers - Page 2




                                        - 2 -                                         
                                        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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