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Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6654(a)
1991 $11,376 $6,933 $34
1992 15,885 9,727 553
1993 23,398 17,549 981
After concessions, the issues for decision are: (1) Whether
petitioner failed to report wages from her employment, interest
income, and unemployment compensation, and (2) whether petitioner
is liable for additions to tax under section 6654(a)1 for her
failure to pay estimated taxes. Respondent has conceded that
petitioner is not liable for the additions to tax under section
6651(f).
Procedural Background
On August 19, 1996, respondent filed a Motion to Show Cause
pursuant to Rule 91(f) as to why facts and evidence set forth in
her proposed stipulation of facts should not be accepted as
established. On September 17, 1996, petitioner filed a response
to this Court's order to show cause. After due consideration,
this Court ordered on September 20, 1996, that facts and evidence
set forth in respondent's proposed stipulation of facts were
deemed to be established for purposes of this case.
Facts Deemed Admitted
At the time the petition in this case was filed, petitioner
resided in Visalia, California. During 1991 and 1992, petitioner
1 All section and subtitle references are to the Internal
Revenue Code in effect for the taxable years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure, unless otherwise designated.
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Last modified: May 25, 2011