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Additions to Tax and Penalty, I.R.C.
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6654 6662(c)
Steven and Jean L. Liddane
1993 $ 9,854 $ 667 $ 78 $ 533
1994 9,333 2,333 480 1,867
Steven J. Liddane
1995 $14,690 $3,673 $797 --
All section references are to the Internal Revenue Code in effect
for the years in issue. All of the facts have been stipulated,
and these cases were submitted for decisions pursuant to Rule
122, Tax Court Rules of Practice and Procedure.
Petitioners resided in Oregon at the time that they filed
their petitions. During the years in issue, petitioner Steven J.
Liddane was employed by Transaero, Inc. Steven J. Liddane
received wages from his employment with Transaero, Inc., in the
amounts of $63,112 in 1993, $62,216 in 1994, and $65,900 in 1995.
Petitioners received $33 in interest income from Midlantic
National Bank in 1993.
Petitioners did not file timely Federal income tax returns
for 1993, 1994, or 1995. Petitioners filed joint Forms 1040 for
1993 and 1994 no earlier than September 1995. No return was
filed for 1995. On the untimely Forms 1040 for 1993 and 1994,
petitioners inserted zeros in each line for income, deductions,
credits, and calculation of tax owing. They did not report on
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Last modified: May 25, 2011