Bill Max Overton - Page 2

                                        - 2 -                                         
                                        Additions to Tax                              
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6654                 
               1996      $4,195         $1,009              $214                      
               1997      4,377          993                 210                       
               1998      3,908               977            179                       

          The issues for decision are:  (1) Whether petitioner received               
          unreported interest income as determined in the notices of                  
          deficiency, and (2) whether petitioner is liable for additions to           
          tax pursuant to sections 6651(a)(1) and 6654 for the years at               
          issue.                                                                      
                                     Background                                       
               When he petitioned this Court, petitioner resided in                   
          Oklahoma City, Oklahoma.                                                    
               For each year at issue, petitioner received interest income            
          from numerous financial institutions.  The interest income                  
          totaled $39,648, $36,859, and $32,683 for 1996, 1997, and 1998,             
          respectively.2                                                              
               Petitioner filed no Federal income tax return for 1996 or              
          1997.  On May 7, 1999, the Internal Revenue Service received from           
          petitioner a Form 1040, U.S. Individual Income Tax Return, for              
          his 1998 tax year.  This document (the purported 1998 return)               


               1(...continued)                                                        
          (RRA 1998), Pub. L. 105-206, sec. 3001, 112 Stat. 726).  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
               2 Petitioner admits in his petition that he received those             
          amounts of interest income.                                                 





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