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Respondent determined the following deficiencies in Federal
income taxes and additions to tax against petitioner for the
years shown:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1991 $2,284 $340 $ 73
1992 2,351 520 90
1993 2,426 607 101
The adjustments giving rise to the above deficiencies and
additions to tax are based upon the failure of petitioner to file
Federal income tax returns and to report the following income for
the years indicated:
1991 1992 1993
U.S. Civil Service Retirement $18,420 $19,092 $19,656
Social Security 1,818 1,884 1,944
Interest income 4 3 3
At the time the petition was filed, petitioner's legal
residence was Sandy, Utah.
The sole issues for decision are whether the above amounts
constitute gross income, and, if so, whether petitioner is liable
for the additions to tax.
At trial, petitioner admitted that he did not file Federal
income tax returns for the years 1991, 1992, and 1993.
Petitioner admitted that, in prior years, he had filed income tax
returns.
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