- 4 - determinations for both 1991 and 1992 include adjustments for self-employment tax under section 1401 and tax on premature distributions from individual retirement accounts under section 72(t). The penalty under section 6662(a) and (c) is based on respondent's determination that the underpayment of tax on petitioner's 1991 tax return is due to negligence or disregard or rules or regulations. The addition to tax under section 6651(a)(1) is based on respondent's determination that petitioner's failure to timely file an income tax return for 1992 was not due to reasonable cause. The addition to tax under section 6654(a) is based on respondent's determination that petitioner failed to pay the requisite amount of estimated income taxes for 1992. Petitioner filed an imperfect petition on January 30, 1995.2 Petitioner filed an amended petition on February 6, 1995, as directed by an Order of the Court dated February 1, 1995. The amended petition states in pertinent part: Notice of Deficiency is fraudulent, as it is based on a Virgin Islands, Non-taxable return, per transaction code 150 and DLN posted to petitioner's IMF pursuant to IRM3. Respondent filed an answer to the amended petition on April 5, 1995. Petitioner then filed a reply to respondent's answer, 2 At the time the petition was filed, petitioner resided at Richmond, Va.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011