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1992
Income Payor Amount
Wages1 University Hospitals
of Cleveland, Ohio $33,356
1Respondent has given petitioner credit for amounts withheld
from petitioner's taxes insofar as petitioner's ultimate tax
liability is concerned. However, the determination of a
statutory deficiency does not take such amounts into account.
See sec. 6211(b)(1).
1993
Income Payor Amount
Wages1 University Hospitals
of Cleveland, Ohio $34,705
Self-employment
income2 A.F. Feo, PhD & Assoc. 6,547
1See supra note 1.
2The deficiency in income tax for 1993 includes self-
employment tax pursuant to sec. 1401.
The additions to tax under section 6651(a)(1) are based on
respondent's determination that petitioner's failure to timely
file income tax returns for the taxable years in issue was not
due to reasonable cause. Finally, the addition to tax under
section 6654(a) is based on respondent's determination that
petitioner failed to pay the required amount of estimated taxes
for 1993.
Petitioner's Petition
Petitioner filed her petition, a 23-page typewritten
document, on December 15, 1995. The crux of petitioner's
position appears to be that respondent acted illegally, and in
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