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years at issue in amounts greater than allowed by respondent; and
(6) whether petitioner is liable for additions to tax under
section 6651(a)(1) for the years at issue and under sections
6651(a)(2) and 6654 for 2000.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Highlands Ranch, Colorado, when the amended petition was filed.
During the years at issue, petitioner operated a commercial
construction business as a sole proprietorship under the name
Coastal Builders. Petitioner provided framing, drywall, plaster
finishing, and painting services. Most of petitioner’s business
came from subcontract work for JPI Apartment Management and/or
JPI Apartment Construction, L.P. (JPI).
In 2001, JPI initiated an internal audit of petitioner and
discovered that the Social Security number he provided to JPI
actually belonged to his son. On January 31, 2002, JPI filed
with the Internal Revenue Service (IRS) and mailed to petitioner
corrected Forms 1099-MISC, Miscellaneous Income, for 1999 and
2000, and an accurate Form 1099-MISC for 2001 using petitioner’s
Social Security number. JPI reported it paid petitioner
$3,130,417, $8,240,832, and $2,573,626, in the respective years
at issue.
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