James M. Abraham - Page 3

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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.                                                                                    
                  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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