- 2 -
Accuracy-
Additions to Tax related Penalty
Year Deficiency Sec. 6651(a)(1)1 Sec. 6654 Sec. 6662(a)
1992 $16,442 $2,822 -- $3,264
1993 17,378 4,170 $728 --
1994 16,174 4,044 839 --
1995 46,117 11,529 2,501 --
We must decide whether respondent's determinations for each
of the years at issue should be sustained. We hold that they
should except to the extent stated herein.
Background
Some of the facts have been stipulated and are so found.
Petitioner lived in or near Boulder, Colorado, at the time
the petition was filed.
In April 1994, petitioner filed an individual income tax
return (return) for 1992. Petitioner failed to file returns for
1993, 1994, and 1995.
On December 31, 1996, respondent issued a notice of defi-
ciency (notice) to petitioner for his taxable years 1992, 1993,
and 1994, and on December 16, 1996, respondent issued a notice to
petitioner for his taxable year 1995.
Respondent determined in the notices, inter alia, that
during the years at issue petitioner received income consisting
of nonemployee compensation, rent, dividends, unemployment
compensation, a premature distribution from an individual retire-
1 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011