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182.1 Respondent determined deficiencies in petitioner's Federal
income tax and additions to tax as follows:
______Additions to Tax_______
Year Deficiency Sec. 6651(a) Sec. 6654
1989 $2,119 $530 $144
1990 2,456 614 160
1991 2,584 100 ---
The issues for decision are: (1) Whether petitioner is
liable for Federal income taxes on wages received during the
years in issue; (2) whether section 6501 bars the assessment and
collection of taxes when a taxpayer fails to file returns; (3)
whether petitioner is liable for additions to tax pursuant to
section 6651(a); and (4) whether petitioner is liable for
additions to tax pursuant to section 6654.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Sumner,
Washington, on the date the petition was filed in this case.
Petitioner failed to file Federal income tax returns for the
taxable years 1989, 1990, and 1991, despite having received wages
in the amounts of $19,214.85, $21,674.30 and $22,786.62 for those
years, respectively. Respondent determined deficiencies in
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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