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income tax, an addition to tax of $1,255 under section 6651(a)
for late filing, and an accuracy-related penalty under section
6662 for negligence.
Background
Petitioners resided in Lebanon, New Jersey, when they filed
their petition. Petitioners filed responses to respondent's
request for admissions, and the parties filed a stipulation of
facts.
During 1992, petitioner Steven J. Liddane (petitioner) was
employed by Transaero Corp., from which he received wages of
$65,128 on which Federal income tax of $5,595 was withheld.
Petitioner Jean L. Liddane is a housewife.
Petitioners did not file a timely 1992 Federal income tax
return, and the omission came to respondent's attention. In July
1994, petitioners received respondent's Form CP-516 notice,
stating that, in order to receive a refund of the previous year's
withholding credit, petitioners needed to submit a return.
On December 6, 1994, the Brookhaven Service Center received
a Form 1040, U.S. Individual Income Tax Return, signed by
petitioners, on which they displayed their Social Security
numbers in the appropriate boxes and claimed joint return filing
status. The return showed zeros on lines 7 through 23, line 52,
and line 64, on which items of gross income, adjusted gross
income, and “the AMOUNT YOU OWE”, respectively, are to be
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