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Respondent determined deficiencies in petitioner's Federal
income taxes for 1992, 1993, and 1994 in the amounts of $1,204,
$2,701, and $3,199, respectively, and additions to tax pursuant
to section 6651(a)(1) in the amounts of $280, $465, and $555,
respectively.
The issues for decision are: (1) Whether petitioner
received and failed to report income during the taxable years in
issue; (2) petitioner's proper filing status for the taxable
years in issue; (3) whether petitioner is entitled to dependency
exemption deductions for his two sons for the taxable years in
issue; (4) whether petitioner is liable for the section
6651(a)(1) additions to tax for failure to file his 1992, 1993,
and 1994 returns; and (5) whether we should impose a penalty on
petitioner pursuant to section 6673(a).
Petitioner resided in Tempe, Arizona, on the date the
petition was filed in this case. No stipulations of fact were
filed in this case.
Petitioner was married and supported his two sons during the
taxable years in issue.
Village Auto Electric reported to respondent that it paid
petitioner employee wages in the amount of $8,481 during 1992.
Arizona Department of Economic Security (Arizona DES) reported to
respondent that it paid petitioner unemployment compensation in
the amount of $5,437 during 1992.
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