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180, 181, and 182.2 In six notices of deficiency, one dated
October 19, 1993, and the other five dated June 22, 1993,
respondent determined the following deficiencies in and additions
to petitioner's Federal income tax:
Additions To Tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1986 $1,406 $352 --
1987 1,649 412 --
1988 3,001 750 --
1989 2,745 686 $187
1990 2,434 593 155
1991 2,389 597 139
The issues for decision are: (1) Whether petitioner is
liable for tax on her income for the years in issue as determined
by respondent; (2) whether petitioner is liable for additions to
tax under section 6651(a) for failure to file returns for the
taxable years in issue; (3) whether petitioner is liable for
additions to tax under section 6654(a) for failure to pay
estimated taxes for taxable years 1989, 1990, and 1991; and (4)
whether a penalty pursuant to section 6673(a) should be imposed
on petitioner.
FINDINGS OF FACT
Prior to consolidation of these cases, docket No. 20150-93
came on for trial on May 23, 1994. We continued that case
2 All section references are to the Internal Revenue Code in
effect for the years at issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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