- 2 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011