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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. On
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