Arlie G. Curry, Jr. - Page 2

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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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