-3-
(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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