- 2 - Federal income tax in the amount of $1,249 and an addition to tax pursuant to section 6651(a) in the amount of $312.25. The issues for decision are: (1) Whether petitioner is liable for Federal income tax on the proceeds from the sale of property and Social Security benefits received during the year in issue; (2) whether section 6501 bars assessment and collection of petitioner's tax; and (3) whether petitioner is liable for an addition to tax pursuant to section 6651(a). Some of the facts have been stipulated and are so found. The stipulations of fact and attached exhibits are incorporated herein by this reference. Petitioner resided in Issaquah, Washington, on the date the petition was filed in this case. Petitioner failed to file his Federal income tax return for the taxable year 1989 despite receiving proceeds from the sale of property in the amount of $10,500 and Social Security benefits in the amount of $4,884. Respondent determined a deficiency in petitioner's Federal income tax based on a "Seller's Tax Reporting Information for I.R.S." form prepared by Puget Sound Mortgage & Escrow, Inc. (Information Report)2 and Form 1099-SSA and determined an addition to tax thereon. issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 The Information Report was filed by the mortgage company conducting the settlement of petitioner's property.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011