Charles A. Nerad - Page 4




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          stated that during 1992 his employer's payroll processing center            
          had moved and that he did not have an accurate wage statement               
          when he filed his income tax return for 1992.  Petitioner further           
          explained that he completed the 1992 income tax return to the               
          best of his ability and that he had requested a corrected wage              
          statement.                                                                  
               On August 2, 1995, respondent sent a letter to petitioner              
          and Ms. Duncan proposing an income tax deficiency for 1992.  On             
          August 10, 1995, petitioner again informed respondent that he had           
          not received a corrected wage statement from his employer and               
          that when, and if, he received a corrected wage statement, he               
          would pay the proper tax.                                                   
               On October 18, 1995, respondent sent petitioner and Ms.                
          Duncan a notice that determined a deficiency in Federal income              
          tax for 1992 in the amount of $6,958 and an accuracy-related                
          penalty under section 6662(a) in the amount of $882.  The                   
          deficiency and penalty were based upon an increase in                       
          petitioner's adjusted gross income, as well as a resulting                  
          computational adjustment to claimed medical expenses.  Petitioner           
          and Ms. Duncan did not file a petition with this Court seeking a            
          redetermination of the deficiency and penalty.  Thus, on March              
          18, 1996, respondent assessed the deficiency in income tax and              
          interest due in the amounts of $6,958 and $1,064, respectively.             
          The penalty under section 6662(a) was not assessed.  Additional             






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