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1991 13,391 3,192 728
After concessions, the issues for decision are:1 (1) Whether
petitioner's motion to dismiss for lack of jurisdiction should be
granted. We hold that it should not. (2) Whether petitioner
received unreported income for taxable years 1989, 1990, and
1991. We hold that he did. (3) Whether petitioner is liable for
section 6651(a) additions to tax for failure to file a Federal
income tax return for each of the years in issue.2 We hold that
he is. (4) Whether petitioner is liable for section 6654(a)
additions to tax for failure to pay estimated taxes for each of
the years in issue. We hold that he is.
We find the following facts based upon the pleadings of this
case and the deemed admissions contained in respondent's request
for admissions.
FINDINGS OF FACT
At the time the petition was filed, petitioner resided in
Santa Clara, California.
The case was set for trial on December 4, 1995. Petitioner
was served with the Court's Standing Pre-Trial Order on June 29,
1 At trial, respondent conceded that petitioner's
deficiency for 1989 is $18,609, reduced from the original amount
of $58,895. Correspondingly, for 1989, the addition to tax
pursuant to sec. 6651(a) is $3,574, and the addition to tax
pursuant to sec. 6654(a) is $394. These concessions will be
given effect under Rule 155.
2 All section references are to the Internal Revenue Code
in effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
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