Robert L. Hawes - Page 2




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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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