- 3 - 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 isPage: Previous 1 2 3 4 5 Next
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