-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 1,000Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008