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Background
The record establishes and/or the parties do not dispute the
following.
A. Petitioner’s Failure To File
Petitioner has a history of failing to file Federal income
tax returns. Specifically, petitioner failed to file a Federal
income tax return for 1992.
B. Respondent’s Notice of Deficiency
On December 28, 1994, respondent issued a notice of
deficiency to petitioner. In the notice, respondent determined,
in pertinent part, a deficiency in petitioner’s Federal income
tax for 1992 in the amount of $15,402, an addition to tax under
section 6651(a)(1) for failure to timely file a tax return in the
amount of $4,544.60, and an addition to tax under section 6654(a)
for failure to pay estimated tax in the amount of $635.78.2 The
deficiency was based principally on respondent’s determination
that petitioner failed to report: (1) Wage income in the amount
of $16,936 (as reported to respondent on Form W-2 by Granite
Construction Co.); (2) nonemployee compensation in the amount of
$43,624; and (3) unemployment compensation in the amount of
$6,095 (as reported to respondent on Form 1099-G).
2 Although the notice of deficiency also sets forth
respondent’s determination of deficiencies in petitioner’s
Federal income taxes for 1990 and 1991, we are concerned in this
proceeding only with petitioner’s liability for 1992.
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Last modified: May 25, 2011