- 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...)
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