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$300.54, respectively, and an accuracy-related penalty under
section 6662(a) in the amount of $2,192.80. By separate notice
of deficiency, respondent determined an $8,817.80 deficiency in
Gary Fujita's (petitioner) 1995 Federal income tax and additions
to tax under sections 6651(a) and 6654(a) in the amounts of
$1,713.70 and $359.86, respectively. By separate notice of
deficiency, respondent determined a $2,404 deficiency in Karen
Fujita's (Mrs. Fujita) 1995 Federal income tax and an addition to
tax under section 6651(a) in the amount of $403.25.
The issues for decision are:2 (1) Whether for 1994 and 1995
petitioners are properly subject to Federal income tax. We hold
they are. (2) Whether for 1994 and 1995 petitioners are liable
for additions to tax under section 6651(a). We hold they are.
(3) Whether for 1994 petitioners are liable for an addition to
tax under section 6654(a). We lack jurisdiction to decide this
issue. (4) Whether for 1994 petitioners are liable for an
accuracy-related penalty under section 6662(a). We hold they
1(...continued)
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
2The parties stipulated that "The sole issue to be decided
by the Tax Court in this case is whether wages paid to a private
individual by a private employer constitute property subject to
federal income taxation." We shall not be bound by this
stipulation, however, as it does not take into consideration the
additions to tax and accuracy-related penalty or that petitioners
had income from sources other than wages.
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