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Respondent determined deficiencies in petitioner's Federal
income taxes for 1991 and 1993 in the amounts of $6,154 and
$6,290, respectively, additions to tax pursuant to section
6651(a)(1) in the amounts of $1,539 and $1,573, respectively, and
additions to tax pursuant to section 6654(a) in the amounts of
$296 and $62, respectively.
The issues for decision are: (1) Whether petitioner has
proved any error in respondent's determinations in the statutory
notice of deficiency, and (2) whether we should, sua sponte,
impose a penalty on petitioner pursuant to section 6673(a).
No stipulations of fact were filed in this case. Petitioner
resided in Las Vegas, Nevada, on the date the petition was filed
in this case.
Petitioner did not file Federal income tax returns for the
taxable years in issue. In a statutory notice of deficiency,
respondent determined that petitioner received and failed to
report gross income from various sources during the taxable years
in issue, including employee wages, nonemployee compensation,
unemployment compensation, and interest income. Respondent also
determined that petitioner is liable for the section 6651(a)(1)
additions to tax for failing to file his returns for the taxable
years in issue. Respondent also determined that petitioner is
liable for the section 6654(a) additions to tax for failing to
make estimated tax payments for the taxable years in issue.
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Last modified: May 25, 2011