Steven Wesley Noe - Page 3




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          tax determined by respondent with respect to petitioner for 1992            
          and 1993 are set forth above.  During 1992, petitioner received             
          wages from Sunshine Nursing Homes, Inc., in the amount of $6,726,           
          from New Hope, Inc., in the amount of $1,142, and from Inland               
          Nurse Providers, Inc., in the amount $2,810.  During 1993,                  
          petitioner received wages from Loganhurst Health Care in the                
          amount of $7,908.  In 1993, petitioner also received unemployment           
          compensation from the State of Washington in the amount of                  
          $2,278.  The fact of these payments and the amounts have been               
          stipulated by the parties.  Petitioner and respondent have                  
          stipulated that if petitioner had filed a tax return for 1992 and           
          1993, he would be entitled to no more than a standard deduction             
          based on single filing status for those years.  The parties also            
          have stipulated that in 1992, $71 was withheld from petitioner's            
          wages by Inland Nurse Providers, Inc., and that petitioner made             
          no other payments of estimated tax for 1992 and no payments of              
          estimated tax whatsoever for 1993.                                          
               At trial, respondent moved for a penalty under section 6673            
          against petitioner on the grounds that he had instituted and                
          maintained the proceedings primarily for delay and that his                 
          positions were frivolous and groundless.                                    
          Discussion                                                                  
               Petitioner presented no evidence at trial to refute                    
          respondent's determinations.  He stipulated to the amount of his            






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