- 3 - 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 hisPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011