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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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