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Additions to Tax
Year Deficiency Sec. 6651 Sec. 6654
1984 $4,086 $677 $149
1985 5,348 871 173
1986 6,076 971 162
1987 72,764 17,607 3,395
1988 5,199 698 161
1989 5,583 748 183
1990 5,962 796 189
1991 6,183 824 171
1992 6,626 1,039 170
All section references are to the Internal Revenue Code
as in effect during the years in issue.
Petitioner did not file a timely income tax return
for any of the above taxable years. Respondent computed
petitioner's tax for each of those years on the basis of
the wages, pension income, interest income, and capital
gains reported to the Internal Revenue Service and
determined the above deficiencies and additions in the
subject notice of deficiency. Petitioner bears the burden
of proving that the tax deficiencies and additions to tax
determined by respondent are wrong. Rule 142(a). All
Rule references are to the Tax Court Rules of Practice and
Procedure. The issue for decision is whether petitioner
has met that burden.
Petitioner resided in Bushkill, Pennsylvania, at the
time he filed the instant petition. The petition states
as follows:
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Last modified: May 25, 2011