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additions to tax under section 6654(a) of $275.03 and $320.77 for
the years in issue, respectively.
After concessions by the parties, the issues for decision
are:
(1) Whether compensation that petitioner received in 2000
and 2001 is taxable to him;
(2) whether petitioner is entitled to itemized deductions
for the years in issue;
(3) whether petitioner is liable for the addition to tax
under section 6651(a)(1) for 2000; and
(4) whether petitioner is liable for the addition to tax
under section 6654(a) for the years in issue.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner had a mailing address in Syracuse, New York, at the
time that he filed his petition.
Petitioner is a member of the Onondaga, a constituent Nation
of the Iroquois Confederacy. Petitioner worked for Ridley
Electric Co., Inc. (Ridley), during the years in issue. While
employed by Ridley, petitioner worked mainly on commercial
buildings, in particular, the Turning Stone Casino. In 2000,
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