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OPINION OF THE SPECIAL TRIAL JUDGE
DEAN, Special Trial Judge: This matter is before the Court
on respondent's Motion for Summary Judgment. Respondent contends
that she is entitled to summary judgment on the ground there is
no genuine issue as to any material fact and a decision may be
entered as a matter of law.
Background
On March 31, 1995, respondent issued a statutory notice of
deficiency to petitioner determining Federal income tax
deficiencies and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1991 $6,725 $1,681 $79
1992 8,662 2,166 378
1993 22,523 5,631 942
The deficiencies in petitioner's income taxes are based on
respondent's determination that petitioner failed to report a
number of items of income for the years 1991, 1992, and 1993,
including gross receipts from a trade or business, interest,
dividends, and proceeds from the sale or redemption of
securities.
The addition to tax under section 6651(a)(1) is based on
respondent's determination that petitioner's failure to file
timely an income tax return for each of the years at issue was
not due to reasonable cause. The addition to tax under section
6654(a) is based on respondent's determination that petitioner
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