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JOHNSTON v. COMMISSIONER

Docket No. 3699-99.

80 T.C.M. 477 (2000)

T.C. Memo. 2000-315

Kevin R. Johnston v. Commissioner.

United States Tax Court.

Filed October 6, 2000.

Attorney(s) appearing for the Case

Kevin R. Johnston, pro se. Sherri S. Wilder, Nicholas J. Richards, and Miles D. Friedman, for the respondent.

MEMORANDUM OPINION

BEGHE, Judge:

Respondent determined a deficiency of $34,541 in petitioner's Federal income and self-employment tax for 1993. Respondent also determined additions to tax under section 6651(a)(1)1 for failure to file a return and under section 6654 for failure to pay estimated tax, of $8,635 and $1,447, respectively.

We must decide whether petitioner's gross income includes certain payments made during...

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