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petitioner’s Federal income taxes for the years and in the
amounts as follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1995 $7,852 $1,860.00 —–- $403.63
1996 15,917 2,472.75 $2,088.10 555.80
1997 12,210 2,747.25 1,587.30 657.80
The issues for decision are as follows:
(1) Whether petitioner filed a Federal income tax return for
any of the years in issue. We hold that he did not.
(2) Whether petitioner is liable for the deficiencies in
income taxes and the additions to tax as determined by respondent
in the notices of deficiency. We hold that he is.
(3) Whether respondent erroneously credited overpayments
allegedly claimed by petitioner on returns for prior years
against past due child support, liability for which petitioner
disputes. We hold that we lack jurisdiction to decide this
matter.
Background2
Some of the facts have been stipulated, and they are so
found. Petitioner resided in North Buena Vista, Iowa, at the
time that his petition was filed with the Court.
2 The documentary record that was developed at trial was
unsatisfactory. Accordingly, the Court held the record open for
60 days so that the parties could produce specific documentary
evidence. Respondent produced what was requested; petitioner did
not.
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