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Federal income tax, an addition to tax of $1,911.50 under section
6651(a) for failure to file an income tax return, and an addition
to tax of $331.20 under section 6654(a) for failure to make
payments of estimated tax.
Background
The parties have stipulated that during 1992 petitioner
received total wage income of $44,506 from three employers
(Telecable Supply Corp., Lynn Electronics Corp., and Dial America
Marketing, Inc.) and had income tax withholding of only $380, and
that petitioner did not file an income tax return or make any
estimated tax payments for the year.
Respondent’s statutory notice based its determination on
reports by the payers of wages paid, allowed a personal exemption
allowance and the standard deduction, and computed the tax based
on single filing status. The statutory notice, in its “Summary
of Income Sources”, also refers to an “aggregate” loss of $3,673
and “realized” loss of $1,023 “paid” to petitioner by Lind-
Waldock & Co. but does not take any such loss into account in
computing petitioner’s tax liability.
Petitioner was a resident of Port Richey, Florida, at the
time of filing her petition. Paragraph 4 of the petition, in
which we would expect to find assignments of error, states in its
entirety as follows: “Petitioner did not engage in any income
excise taxable activities during the year in question, and Title
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