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6651(a) for late filing, and an addition to tax of $1,462 under
section 6654(a) for failure to pay estimated taxes with respect
to petitioner's 1995 Federal income tax.
Background
Petitioner resided in Houston, Texas, when he filed his
petition.
The notice of deficiency includes an explanation that the
adjustments made to petitioner's taxable income are attributable
to petitioner's failure to file a 1995 tax return and to report
various items of income including: (1) Nonemployee compensation
paid by Lincoln Investment Planning, Inc., General American Life
Insurance Co., and Willow Fork Drainage District; (2) interest
paid by Charles Schwab & Co. and Texas Commerce Bank; (3)
dividends paid by Pioneer U.S. Government Money Fund and All
Saints Credit Union; and (4) gains derived from stock sales in
1995. These items of income were reported to respondent on Forms
1099 and other information returns submitted by the payors.
Petitioner invoked this Court's jurisdiction by filing an
imperfect petition for redetermination, followed by an amended
petition. Respondent filed a timely answer to the amended
petition.
Respondent subsequently served petitioner with a request for
admissions (with attached exhibits) pursuant to Rule 90(a) and
filed the same with the Court pursuant to Rule 90(b). Petitioner
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