This case is before the Court on respondent's Motion To
Dismiss For Failure To State A Claim Upon Which Relief Can Be
Granted, filed pursuant to Rule 40. John S. Black (petitioner)
resided in Las Vegas, Nevada, at the time that the petition was
filed in this case.
Respondent's Notices of Deficiency
By separate notices, each dated March 24, 1995, respondent
determined deficiencies in, and additions to, petitioner's
Federal income taxes for the taxable years 1991 and 1992 as
follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1991 $3,844 $601.50 $128.38
1992 6,067 714.00 109.01
The deficiency in income tax for 1991 is based on
respondent's determination that petitioner failed to report on an
income tax return for the taxable year 1991: (1) Wages from
three separate payors in the amounts of $5,568, $3,265, and
$9,411, respectively; (2) unemployment compensation in the amount
of $6,973; (3) short-term capital gains in the amount of $3,488;
and (4) dividend income in the amount of $5. The deficiency in
income tax for 1992 is based on respondent's determination that
petitioner failed to report on an income tax return for the
taxable year 1992: (1) Wages in the amount of $34,481; and (2)
unemployment compensation in the amount of $3,036. The additions
1(...continued)
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