Ruth R. Johnson-Straub - Page 3

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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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