- 7 - did, however, maintain a car during the years in issue, a 1979 Ford Pinto. Petitioner has disproven that he had the additional income determined by respondent by showing that his expenses were in fact less than would be inferable from the Bureau of Labor Statistics' data and did not exceed the amounts of wages and nonemployee compensation identified above. Accordingly, we hold that petitioner is not liable for the additional deficiencies determined by respondent's utilizing Bureau of Labor Statistics' data for the years in issue. Issue 3. Addition to Tax Under Section 6651(a)(1) Respondent determined an addition to tax under section 6651(a)(1) for failure to file a return. Petitioner did not file Federal income tax returns for the years in issue. Accordingly, respondent's determination on this issue is sustained. Issue 4. Addition to Tax Under Section 6654(a) Respondent determined an addition to tax under section 6654(a) for underpayment of individual estimated tax. Petitioner failed to pay estimated tax during the years in issue. Accordingly, respondent's determination on this issue is sustained. For the foregoing reasons, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011