Petitioner resided in Latham, Illinois, at the time the
Petition in this case was filed.
Respondent's Notice of Deficiency
On February 9, 1995, respondent mailed to petitioner a
notice of deficiency in which she determined the following
deficiencies and additions to petitioner's Federal income taxes:
Petitioner, Gaylon L. Harrell
Taxable Additions to Tax
Year Ended Deficiency Sec. 6651(a)(1) Sec. 6651(f) Sec. 6654(a)
1991 $3,436 $859 -- $113
1992 3,293 823 -- 79
1993 6,374 -- $2,8681 269
1This is the amount shown in respondent's notice of deficiency except on1
schedule 2 of the notice which shows this addition to tax to be $3,576. We
have no explanation for the discrepancy.
The deficiencies in Federal income tax asserted by
respondent are based on the determination that petitioner
received compensation from the Minneapolis Postal Data Center and
taxable pension distributions from "Caterpillar NCP Trust" during
each of the years 1991, 1992, and 1993, no part of which was
reported on a tax return due for each of the respective years.
The additions to tax under section 6651(a)(1) are based on
respondent's determination that petitioner's failure to file
timely a tax return for 1991 and 1992 was without reasonable
cause. The addition to tax under section 6651(f) for the year
1993 is based upon respondent's determination that petitioner
fraudulently failed to file a tax return for the year 1993. The
additions to tax under section 6654 are based on respondent's
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