- 2 - Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a) Sec. 6654(a) 1993 $2,696 $674.00 $112.93 1994 1,489 372.25 -0- The issues for decision are: (1) Whether the period of limitations under section 6501(a) bars respondent from making assessments against petitioner for the years 1993 and 1994; (2) whether, for 1993 and 1994, petitioner realized a gain, pursuant to section 1001(a), on the redemption of certain shares of Citizens Federal Bank Non-Cumulative Preferred Stock (Citizens Federal Stock); (3) whether, for 1993 and 1994, petitioner was engaged in a trade or business activity under section 162(a); (4) whether petitioner is liable for the addition to tax under section 6651(a) for failure to file returns for 1993 and 1994; and (5) whether, for 1993, petitioner is liable for the addition to tax under section 6654(a) for failure to make estimated tax payments.2 2 Issue number 1 was presented by petitioner at trial by way of a motion to dismiss for lack of jurisdiction on the ground that respondent was barred by the period of limitations under sec. 6501(a). Respondent filed an objection, affirmatively alleging that the notices of deficiency were not barred because petitioner did not file Federal income tax returns for the 2 years at issue. The Court denied petitioner's motion to dismiss (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011