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April 18, 1997, respondent issued a statutory notice of
deficiency for petitioner for 1994 based upon taxable income
reports to the Internal Revenue Service (IRS) received from
Hidden Valley Ranch, Inc., and from the U.S. Department of the
Treasury (Treasury Department). The report from Hidden Valley
Ranch, Inc., reported wages paid to petitioner in the amount of
$15,560 for 1994. The report from the Treasury Department
reported interest income paid to petitioner in the amount of $94
for 1994.
Discussion
Petitioner presented no evidence at trial to refute
respondent's determination of deficiency. To the contrary,
petitioner has stipulated that he received $15,560 of wages from
Hidden Valley Ranch, Inc., and $94 of interest income from the
Treasury Department. During the trial, petitioner did not
dispute respondent's determination of a deficiency, but instead
stated that his purpose for filing his petition was "to simply be
able to become an up-to-date taxpayer and pay my taxes from '94 *
* * without having to pay penalties or interest on those years."
Since petitioner does not deny that he owes the amount of the
deficiency, we sustain respondent's determination of the
deficiency in petitioner's income tax for 1994.
Section 6651(a) imposes an addition to tax for a taxpayer's
failure to file a required return on or before the specified
filing date, including extensions. The addition to tax is
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