- 2 - All Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $1,293 and an addition to tax for failure to file timely a Federal income tax return pursuant to section 6651(a)(1) in the amount of $323.25. We must decide the following issues: (1) Whether petitioner is liable for a deficiency in income tax for 1994 in the amount of $1,293. We hold that he is. (2) Whether petitioner is liable for an addition to tax in the amount of $323.25 under section 6651(a)(1) for failure to file timely an income tax return for 1994. We hold that he is. (3) Whether petitioner is entitled to a jury trial in deficiency proceedings in the U.S. Tax Court with respect to the above-mentioned issues concerning his income tax liability for 1994. We hold that he is not. (4) Whether petitioner is liable for a penalty under section 6673(a). We hold that he is liable for such a penalty and require him to pay to the United States a penalty of $500. Background Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Escondido, California, when his petition was filed. Petitioner did not file a Federal income tax return for the year 1994. OnPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011