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Respondent determined a deficiency in petitioner's 1994
Federal income tax in the amount of $2,171 and an addition to tax
pursuant to section 6651(a)(1) in the amount of $540.
Respondent concedes the deficiency and addition to tax in
full; thus, the only issue in dispute is whether petitioner is
entitled to an overpayment in the amount of $11.
At the time of filing the petition herein, petitioner
resided at Spring City, Pennsylvania.
During the taxable year 1994, petitioner received taxable
income. The taxable income was reported by various third-party
payors from "stock/bond" sales, "pension/annuities", dividends,
and interest. With respect to two of petitioner's bank accounts,
there were withholding credits totaling $11.
Petitioner did not file a Federal income tax return for the
taxable year 1994. Respondent mailed a notice of deficiency to
petitioner on May 11, 1998, determining the deficiency and
addition to tax. The notice of deficiency determined that
petitioner failed to file a return and failed to report various
items of taxable income referred to above. After petitioner
provided certain information to representatives of the Internal
Revenue Service (IRS), and after a review of this matter by the
IRS Appeals Office, respondent concluded that petitioner was not
required to file a Federal income tax return and was not liable
for a deficiency or an addition to tax.
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Last modified: May 25, 2011