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Respondent determined a deficiency in petitioner's Federal
income tax for 1994 in the amount of $2,872, an addition to tax
pursuant to section 6651(a)(1) in the amount of $718, and an
addition to tax pursuant to section 6654(a) in the amount of
$147.99.
The issues for decision are: (1) Whether petitioner has
proved any error in respondent's determinations in the statutory
notice of deficiency, and (2) whether we should, sua sponte,
impose a penalty on petitioner pursuant to section 6673(a).
No stipulations of fact were filed in this case. Petitioner
resided in Carson City, Nevada, on the date the petition was
filed.
Petitioner worked as an appraiser during 1994. Respondent
determined that the following entities paid petitioner the
following amounts for her appraisal services during 1994:
Real Estate Appraisers Office $2,310
First Nationwide Mortgage Corp. 500
Coast Federal Bank 4,175
First Nationwide Bank 6,575
Total 13,560
Petitioner does not deny having received moneys from the above-
mentioned entities for services performed during 1994.
Petitioner did not file a Federal income tax return for her
1994 taxable year. In a statutory notice of deficiency,
respondent determined that petitioner received and failed to
report nonemployee compensation during 1994 in the amount of
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