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Respondent determined a deficiency in petitioner's 1992
Federal income tax in the amount of $5,890 and additions to tax
under sections 6651(a)(1) and 6654 in the amounts of $1,257 and
$241, respectively.
After a concessions by the parties,2 the issues for decision
are: (1) Whether the "wages" received by petitioner are taxable;
(2) whether petitioner is liable for the addition to tax for
failure to file a return pursuant to section 6651(a) in the
amount of $1,257; and (3) whether petitioner is liable for the
addition to tax for underpayment of estimated tax pursuant to
section 6654 in the amount of $241.
No facts have been stipulated. Petitioner resided in
Golden, Colorado, on the date the petition was filed in this
case.
In 1992 petitioner worked for Aspen Office Furniture and
Denver Post from which he received wages in the amounts of
$22,652 and $8,269, respectively. The wages from Aspen Office
Furniture were reported on a Form W-2, Wage and Tax Statement,
and $863 of Federal income tax was withheld. The wages received
from Denver Post were self-employment income, reported on Form-
1099, Miscellaneous Income. In addition, petitioner received a
taxable State income tax refund from the Colorado Department of
2 Respondent conceded that the notice of deficiency did
not reflect petitioner's withholding of $863. Petitioner
conceded that he must include in his gross income a refund of
State income tax.
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Last modified: May 25, 2011