Ted Cowan - Page 2

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          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.                 




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