This case is before the Court on respondent's Motion To
Dismiss For Failure To State A Claim Upon Which Relief Can Be
Granted, as supplemented, filed pursuant to Rule 40.
Petitioner resided in Carthage, Missouri, at the time that
the petition was filed with the Court.
Respondent's Notice of Deficiency
Respondent issued a notice of deficiency to petitioner dated
September 13, 1995. In said notice, respondent determined the
following deficiencies in petitioner's Federal income taxes and
additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1991 $3,949 $976 $224
1992 4,018 995 174
1993 4,293 1,073 182
The deficiencies in income taxes, which include deficiencies in
self-employment taxes, are based on respondent's determination that
petitioner failed to report income as reflected in the following
schedules:
1991
Income Payor Amount
Wages2 Pizza Hut $1,803
Nonemployee
compensation Carthage Press 2,387
Other self-
employment income 13,379
2Respondent has given petitioner credit for amounts withheld from his taxes
insofar as his ultimate tax liability is concerned. However, the determination
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