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Background
Respondent determined deficiencies in, and additions to,
petitioner's Federal income taxes for 1992 and 1993 as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $716 $161 $30
1993 619 155 23
The issues for decision are: (1) Whether petitioner is
subject to the Federal income tax laws and, more specifically,
whether he is required to pay income tax on the wages paid to him
during the years in issue; (2) whether petitioner is liable for
additions to tax under section 6651(a)(1) for failure to file
timely an income tax return for the years 1992 and 1993; (3)
whether petitioner is liable for additions to tax under section
6654(a) for failure to pay estimated income tax for the years
1992 and 1993; and (4) whether petitioner is liable for a penalty
under section 6673(a).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Veradale, Washington, when his petition was filed.
Petitioner did not file Federal income tax returns for the
years 1992 and 1993. On July 11, 1997, respondent issued a
statutory notice of deficiency to petitioner for the years 1992
and 1993 based upon taxable income reports issued by third
parties. The amounts of the deficiencies in tax and additions to
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Last modified: May 25, 2011