Rosemary V. Cocozza - Page 2

                                                 - 2 -                                                   

            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                             





Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011