- 7 -
The amounts of tax withheld from petitioner's wages by Aesthetics
in Jewelry, Inc., did not satisfy his obligations to pay
estimated tax in 1993 and 1994.
At the conclusion of the testimony of respondent's
witnesses, petitioner said that he wanted to submit additional
briefs. The Court warned him that would mean more work for
respondent and the Court, which could result in a larger penalty
under section 6673 than if the Court just ruled from the bench.
Petitioner replied: "I am willing to take that risk". The Court
set a briefing schedule, and briefs have been filed by the
parties.
Notwithstanding that this case has been submitted to the
Court for decision as described above, the case at docket No.
7944-98 was disposed of, on February 18, 1999, by entry of an
agreed decision that reduced the amounts of the deficiencies and
additions originally determined by respondent.
Discussion
Respondent's determinations in this case were based upon
third-party information returns for compensation paid to
petitioner. Petitioner refused to stipulate the amounts
received. In the face of petitioner's refusal, respondent, out
of an abundance of caution in the face of section 6201(d), proved
the amounts received by the testimony and records of petitioner's
former employers and their accountants. Petitioner has not
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011