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section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Special Trial Judge,
which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: In a notice of
deficiency dated December 22, 1995, respondent determined a
deficiency in and additions to petitioner's Federal income tax
for the taxable year 1993 as follows:
Addition to Tax
Deficiency Sec. 6651(a) Sec. 6654(a)
$4,855 $1,214 $192
Respondent determined that petitioner failed to file a
return for the taxable year 1993. The notice of deficiency
included the following adjustments of omitted income:
Name of Payor Kind of Payment Amount
NBD Mortgage Co. Real estate sales $17,900
E.D. Jones & Co.
Daily Passport Cash TST Dividends 18
Achievers Unlimited Nonemployee compensation 15
Fidelity Service Co. IRA distribution 599
Fidelity Service Co. IRA distribution 1,973
A timely petition was filed in response to the notice of
deficiency. In the petition, petitioner alleged that, in
response to Internal Revenue Service (IRS) inquiries, he had
1 All section references are to the Internal Revenue Code
in effect for the year in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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