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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.
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Last modified: May 25, 2011