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In separate notices of deficiency, respondent determined a
deficiency of $574 in petitioner's Federal income tax for 1992,
and a deficiency of $2,719 in petitioner's Federal income tax for
1994, and additions to tax, for 1994, of $429 and $31, under
sections 6651(a)(1) and 6654, respectively.
The issues for decision are: (1) Whether petitioner is
liable for Federal income taxes on income of $2,040.63 for 1992,
and $21,909 for 1994; (2) whether, for 1994, petitioner is liable
for the addition to tax under section 6651(a)(1) for failure to
file timely a Federal income tax return; and (3) whether, for
1994, petitioner is liable for the addition to tax under section
6654 for failure to make estimated tax payments.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was Bridgeton, Missouri.
Petitioner filed timely his Federal income tax return for
1992 reporting gross income of $24,304, consisting of wages,
$23,750; interest income, $379; and unemployment compensation,
$175.2 Petitioner also claimed itemized deductions of $7,009.
2
Attached to petitioner's 1992 return were six Forms W-2,
Wage and Tax Statement (Form W-2), from the following employers
reporting the following wages: (1) The Pasta House Company,
$1,917.22; (2) Crestwood Health and Fitness, Inc., $792.50;
(3) Navy Material Transportation Office, $332.26; (4) TAD
Technical and/or Consultants and Designers, $2,005.50;
(continued...)
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