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Court Rules of Practice and Procedure. The Court agrees with and
adopts the Special Trial Judge's opinion, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge: This case is before the Court
on respondent's Motion To Dismiss For Failure To State A Claim
Upon Which Relief Can Be Granted, filed pursuant to Rule 40.
Respondent determined deficiencies in, and additions to,
petitioner's Federal income taxes as follows:
Additions to Tax Under Section
Year Deficiency 6651(a)(1)
1990 $11,039 $401
1991 14,664 2,547
The deficiency for the year 1990 was based on respondent's
determination that petitioner failed to report wage income of
$21,004 and interest income of $1,598, and on respondent's
disallowance of a partnership loss in the amount of $19,626. The
deficiency for the year 1991 was based on respondent's
determination that petitioner failed to report wage income of
$63,406. The additions to tax under section 6651(a)(1) were
based on respondent's determination that petitioner's failure to
file timely income tax returns for the years 1990 and 1991 was
not due to reasonable cause.
Petitioner resided in Tulsa, Oklahoma, when his petition was
filed.
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