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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $9,245 $1,415 $230
1993 10,896 1,432 216
1994 11,708 1,509 281
The above tax deficiencies do not reflect the fact that
income tax had been withheld from petitioner's wages in the
amount of $3,584 in 1992, $5,167 in 1993, and $5,672 in
1994. Thus, according to the notice of deficiency, the
"net additional tax" due from petitioner in 1992, 1993,
and 1994 is $5,661, $5,729, and $6,036, respectively.
The issues for decision are: (1) Whether petitioner
should be allowed the filing status of married filing
jointly, rather than single; (2) whether petitioner is
entitled to five or six personal exemptions; (3) whether
petitioner realized gain from the sale of stock of his
employer, American Airlines, Inc.; (4) whether petitioner
is entitled to collect $17,732.46 in "damages" from the
Internal Revenue Service and whether petitioner can deduct
$9,000 per year for "the impact the events created on his
ability to earn income, both past, present and future
* * * in additional to any deductions that are otherwise
authorized,"; and (5) whether petitioner is liable for
the addition to tax under section 6651(a)(1) for failure
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Last modified: May 25, 2011