- 4 -
1992
Income Payor Amount
Nonemployee
compensation A M Cabinets, Inc. $2,980
Wages Adwood Corp. 6,780
1993
Income Payor Amount
Wages Adwood Corp. $ 1,130
Wages USX Corp. 24,411
Total 25,541
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 taxable years in issue was not
due to reasonable cause. Finally, the additions to tax under
section 6654(a) are based on respondent's determination that
petitioner failed to pay the requisite amount of estimated taxes
for the taxable years in issue.
Petitioner's Petition and Amended Petition
Petitioner filed his petition on October 11, 1995. The crux
of petitioner's position is that the Commissioner may not
determine a deficiency if a taxpayer has not filed a return.
Thus, the petition includes the allegation that "For the
Commissioner to make an 'examination' a return must exist."
On November 13, 1995, petitioner filed an amended petition.
In his amended petition, petitioner admits that he did not file
income tax returns for the taxable years in issue. Petitioner
also alleges, in part, as follows:
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