Leon Albert Landry - Page 2

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            year in issue, and all Rule references are to the Tax Court Rules                         
            of Practice and Procedure.  The issues for decision are as                                
            follows:                                                                                  
                  1.  Whether petitioner is liable for the deficiency                                 
            determined by respondent.  We hold that he is liable.                                     
                  2.  Whether petitioner, pursuant to section 6651(a)(1), is                          
            liable for an addition to tax for failing to file his 1991                                
            Federal income tax return in a timely manner.  We hold that he is                         
            liable.                                                                                   
                  3.  Whether petitioner, pursuant to section 6654, is liable                         
            for an addition to tax for failing to make estimated tax                                  
            payments.  We hold that he is liable.                                                     
                  4.  Whether petitioner has engaged in behavior that warrants                        
            the imposition of a penalty pursuant to section 6673(a)(1).  We                           
            hold that a penalty is warranted and impose a penalty of $5,000.                          
                                         FINDINGS OF FACT                                             
                  At the time the petition was filed, petitioner resided in                           
            Medfield, Massachusetts.  In 1991, petitioner received $52,568                            
            for services rendered to New England Retail Express, Inc.  He did                         
            not file a 1991 Federal income tax return.                                                
                  On February 27, 1996, respondent issued a notice of                                 
            deficiency to petitioner.  In it, respondent determined that                              
            petitioner, with respect to his 1991 tax year, was liable for a                           
            deficiency and additions to tax pursuant to sections 6651(a)(1)                           
            and 6654.  Respondent mailed the notice to petitioner's residence                         




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