- 5 -
circumstances, we will not look behind a notice of deficiency to
examine the evidence used by the Commissioner in her
determination. Id.
Respondent considered reliable information that related to
petitioner in particular. Attachments to the deficiency notice
identify petitioner's employers and other sources of income.
Nothing on the face of the notice of deficiency indicates that
respondent failed to make a determination with respect to
petitioner's tax liability. We find that respondent satisfied
the requirements of section 6212, and the notice of deficiency
issued to petitioner is valid. Thus, we have jurisdiction over
this case.
Despite petitioner's extensive and well-written arguments on
brief, the factual allegations deemed admitted under Rule 91(f)
establish that petitioner had income for the years in issue which
she failed to report. In addition, petitioner did not present
any evidence contesting respondent's determination that she is
subject to self-employment tax under section 1401. We sustain
respondent's determination as to the deficiencies in petitioner's
Federal income and self-employment taxes.
Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Section 6654(e)
contains exceptions to the application of the addition to tax.
Petitioner bears the burden of proving that she is not liable for
additions to tax. Rule 142(a).
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011