Hulbert v. Commissioner
| Decision Date | 09 October 1973 |
| Docket Number | Docket No. 2536-70. |
| Citation | 1973 TC Memo 221,32 TCM (CCH) 1024 |
| Parties | Corwin L. Hulbert v. Commissioner. |
| Court | U.S. Tax Court |
Corwin L. Hulbert, pro se, 114 L St., Lincoln, Neb. Robert J. Murray, for the respondent.
Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in Federal income taxes and additions to tax against the petitioner as follows:
Additions To Tax
Year Deficiency Sec. 6651(a)1 Sec. 6653(a)
1962 ...... $5,320.37 $1,330.09 $266.02
1965 ...... 1,355.32 432.82 117.31
1 All statutory references are to the Internal
Revenue Code of 1954, as amended, unless
otherwise indicated
Several issues raised in the pleadings have been abandoned by the petitioner and can be given effect in the Rule 50 computation. There are several issues remaining to be decided.
(1) Whether respondent correctly reconstructed the petitioner's adjusted gross income by use of the net worth plus nondeductible expenditures method;
(2) Whether the petitioner is liable for additional self-employment tax in the amount of $77.09 for the taxable year 1965;
(3) Whether the petitioner is liable for additions to the tax under section 6651(a), and
(4) Whether the petitioner is liable for additions to the tax under section 6653(a).
Some of the facts have been stipulated and are so found.2
Corwin L. Hulbert, hereinafter called Hulbert or petitioner, is an individual who at the time the petition in this case was filed resided in Lincoln, Nebraska.
The petitioner filed Federal income tax returns for the taxable years 1962 and 1965 with the district director of internal revenue, Omaha, Nbraska.
The petitioner's Federal income tax return for the taxable year 1962 was received by the Lincoln, Nebraska office of the internal revenue on January 29, 1965.
The Federal income tax return which the petitioner filed for the taxable year 1965 was received on August 12, 1966.
During the taxable years 1962 and 1965 the petitioner owned and operated a farm of approximately 400 acres near Yates Center, Kansas, and another farm containing approximately 80 acres located in Saunders County, Nebraska. During December 1964 petitioner signed a contract for the purchase of an additional 60 acres of Saunders County real property.
During the taxable year 1965 the petitioner sold his entire farm located in Saunders County, Nebraska, for a total consideration of $24,500.
During the years in issue petitioner had an interest in and managed several residential apartment units in Lincoln, Nebraska.
Petitioner failed to maintain adequate books and records of his income and expenditures during the years in issue.
Respondent determined petitioner's adjusted gross income by using the net worth plus nondeductible expenditures method as follows:
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