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Respondent determined deficiencies in petitioner's Federal
income taxes and additions to tax for the years as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1)
1987 $1,004 $251 ---
1988 1,759 275 $88
Additions to Tax
Year Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6654(a)
1987 $50.20 * $48.20
1988 --- --- 95.00
*50% of the interest due on the deficiency.
The issues for decision are: (1) Whether petitioner
received and failed to report income during the taxable years in
issue; (2) whether petitioner is liable for the section
6651(a)(1) additions to tax for failure to file his 1987 and 1988
returns; (3) whether petitioner is liable for the section
6653(a)(1) additions to tax for negligence; (4) whether
petitioner is liable for the section 6654(a) additions to tax for
failure to make estimated income tax payments for 1987 and 1988;
and (5) whether we should impose sanctions on petitioner pursuant
to section 6673(a).
Petitioner resided in Tempe, Arizona, on the date the
petition was filed in this case. No stipulations of fact were
filed in this case.
1(...continued)
Practice and Procedure.
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