Creed J. Pearson - Page 3




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               (3)  whether petitioner is liable for an addition to tax for           
          fraudulent failure to file a return under section 6651(f) or,               
          alternatively, an addition to tax for failure to file a timely              
          return under section 6651(a)(1), for each year in issue.  We hold           
          that he is liable for an addition to tax for failure to file a              
          timely return under section 6651(a)(1) for each year;                       
               (4)  whether petitioner is liable for an addition to tax for           
          failure to pay his tax liability under section 6651(a)(2) for               
          each year in issue.  We hold that he is;                                    
               (5)  whether petitioner is liable for an addition to tax for           
          failure to pay estimated tax under section 6654 for each year in            
          issue.  We hold that he is liable for additions to tax for years            
          2000 through 2003, but not for 1999.                                        
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  The                 
          stipulated facts and the exhibits submitted therewith are                   
          incorporated herein by this reference.                                      
               At the time he filed his petition, petitioner resided in               
          Arlington, Virginia.                                                        
               Petitioner received taxable income of $926,511, $692,617,              
          $1,116,134, $284,120, and $201,718 in 1999, 2000, 2001, 2002, and           
          2003, respectively.  The bulk of this was self-employment income            
          that petitioner received as a hospital reimbursement consultant.            
          During the relevant period, petitioner worked with nearly 1,000             







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