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Respondent determined deficiencies in petitioner's Federal
income taxes and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1993 $3,616 $807 $132
1994 3,359 754 154
Petitioner resided in Fremont, California, at the time he
filed his petition.
After concessions,2 the issues are: (1) Whether petitioner
is liable for the asserted deficiencies and additions to tax, and
(2) whether this Court should impose a penalty upon petitioner
pursuant to section 6673(a)(1).
FINDINGS OF FACT
In the notice of deficiency, respondent determined that
petitioner failed to file Federal income tax returns for the
taxable years 1993 and 1994 and failed to report wages and
allocated tip income for those years as reflected on Forms W-2
issued by the Edward Thomas Hospitality Corp. In addition to the
2 Respondent concedes that the statutory notice of deficiency
should not have included adjustments for the employee's portion
of tax for old-age, survivors, and disability insurance and
hospital insurance (FICA tax) imposed by sec. 3101(a) and (b),
and that the deficiencies and additions to tax must be adjusted
accordingly. Thus, the amounts in dispute are as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1993 $2,471 $520 $86
1994 2,284 485 97
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