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income tax in the amount of $7,228 and an addition to tax under
section 6651(a)(1) in the amount of $215.
The issues for decision are: (1) Whether petitioner
received taxable wages and unemployment compensation in the
amounts determined by respondent and (2) whether petitioner is
liable for the addition to tax under section 6651(a)(1) for
failure to file a return.
The parties were unable to agree on a stipulation of facts
in this case. Our findings of fact are based on the record
consisting of testimony of witnesses and documents submitted into
evidence.
During the period December 1992 through mid-February 1993,
petitioner was unemployed. During the period January 6 through
February 8, 1993, the State of Connecticut issued seven checks in
the amount of $198 each, for a total of $1,386, as unemployment
compensation to petitioner. The Connecticut Department of Labor
records further reflect that each of the seven payments to
petitioner was designated as $288; however, $90 was offset from
each payment to pay an outstanding child support order.
Accordingly, the total payments for unemployment insurance in
1993 paid on behalf of petitioner were $2,016 (7 X $288) although
petitioner was sent checks totaling $1,386 (7 X $198). A total
of $630 was sent to the Connecticut court to be applied against
the outstanding court order for child support. Sometime during
the last week of January 1994, petitioner was sent a Form 1099
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