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and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion to Dismiss for Lack of Jurisdiction. The
question presented is whether petitioner filed his petition
within the 90-day period prescribed by sections 6213(a) and 7502.
Background
On November 30, 1994, respondent mailed five separate
statutory notices of deficiency to petitioner Peter R. Little
(petitioner) determining deficiencies in and additions to his
Federal income taxes for the years and in the amounts as follows:
Additions to tax
Year Deficiency1 Sec. 6651(a)(1) Sec. 6654
1988 $13,470.04 $1,603.01 $359.92
1989 11,297.00 945.75 199.38
1990 22,364.83 2,354.46 525.37
1991 22,352.19 2,017.05 372.79
1992 18,029.00 213.25 ---
1 The deficiencies were determined without regard to either withholding tax
credits under section 31 or credit for certain payments to which petitioner is
entitled. See sec. 6211(b)(1).
The deficiencies in income taxes are based on respondent's
determination that petitioner failed to report substantial income
from Princeton University and the Asia Foundation, as well as
from other sources, on timely filed income tax returns for the
years in issue. The additions to tax under section 6651(a)(1)
are based on respondent's determination that petitioner's failure
to timely file income tax returns for the years in issue was not
due to reasonable cause. Finally, the additions to tax under
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