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)Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011