- 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 TitlePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011