Marian and Maria Juskuv - Page 4




                                        - 4 -                                         
          Adjustment to income                 $10,300                                
          Taxable income per return            167,063                                
          Corrected taxable income             77,363                                 
          Tax--from tax tables                 16,595                                 
          Additional tax on IRA (10 percent)    1,030                                 
          Total corrected tax liability        17,625                                 
          Less:  Tax shown on return           13,711                                 
          Deficiency                            3,914                                 
          1  This amount was computed as follows:                                     
          Wages per return                $78,613                                     
          Total income                     78,613                                     
          Less:                                                                       
          Standard deduction    $6,550                                                
          Exemptions             5,000   11,550                                       
          Taxable income                 67,063                                       

               On the basis of the corrected tax liability of $17,625, less           
          the income withholding of $8,942, respondent determined an                  
          addition to tax under section 6651(a)(1) of $2,171.  Likewise,              
          starting with the $17,625 amount, respondent also determined an             
          addition to tax under section 6654(a) of $364.                              
               Petitioners abandoned their tax protester arguments and                
          filed a Second Amended Petition on March 30, 1998.  In their                
          amended petition, they claimed Schedule C expenses and Schedule E           
          losses and a Schedule D capital loss.                                       
               Simultaneously with the filing of their amended petition,              
          petitioners provided respondent with a revised 1995 Form 1040,              
          signed on March 30, 1998.  On the Form 1040, they included in               
          gross income their previously reported wages.  They also reported           
          distributions of $3,334 and pensions and annuities of $6,967,               
          totaling $10,301.  Therefore, we deem that petitioners have                 





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