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The issues for decision are: (1) Whether petitioner failed to
report income during the year in issue; (2) whether petitioner is
liable for a section 6651(a) addition to tax for failure to file a
1992 Federal income tax return; and (3) whether petitioner is
liable for a section 6654(a) addition to tax for failure to make
estimated tax payments for 1992.
All section references are to the Internal Revenue Code in
effect for the year in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein by this reference.
Background
Clyde Franklin Craig (petitioner) resided in Seattle,
Washington, at the time he filed his petition. Between 1962 and
1965, he studied physics and electrical engineering at UCLA, but
did not graduate. Petitioner has worked in the electronics
engineering field.
Petitioner concedes that he did not file a 1992 Federal income
tax return.
Petitioner's Sources of Income
In 1992, petitioner worked as a television engineer for King
Broadcasting Co. (KBC), a major television broadcast station in the
Seattle area. His duties included maintaining and repairing the
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