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Section 6673, filed pursuant to Rule 40. The Court, sua sponte,
also considers whether to strike portions of the petition under
Rule 52.
Respondent determined deficiencies in, and additions to,
petitioner's Federal income taxes, as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1992 $34,134 $8,534 $1,489
1993 69,478 17,370 2,911
The adjustments giving rise to the above deficiencies and
additions to tax are based upon the failure of petitioner to file
Federal income tax returns and report nonemployee compensation,
dividend income, and income from the sale of stock for the years
in issue. The additions to tax under section 6651(a)(1) were
based on respondent's determination that petitioner's failure to
file income tax returns for the taxable years in issue was not
due to reasonable cause. Finally, the additions to tax under
section 6654(a) were based on respondent's determination that
petitioner failed to pay the requisite estimated income tax for
the taxable years in issue. Petitioner resided in San Clemente,
California, at the time he filed his petition.
Petitioner filed a petition for redetermination on March 19,
1996. In the petition, petitioner disputed the adjustments as
determined by respondent in the notice of deficiency. The
petition contains assignments of error and statements of facts
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