William C. Williams - Page 2




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               Respondent determined a deficiency in petitioner's 1995                
          Federal income tax in the amount of $4,476, an addition to tax              
          for failure to file timely a Federal income tax return pursuant             
          to section 6651(a)(1) in the amount of $947.03, and an addition             
          to tax for failure to pay estimated income tax pursuant to                  
          section 6654 in the amount of $242.70.                                      
               The issues for decision are: (1) Whether petitioner is                 
          exempt from Federal income tax on his compensation for labor                
          during 1995; (2) whether petitioner is liable for an addition to            
          tax under section 6651(a)(1) for failure to file timely a Federal           
          income tax return for the year 1995; (3) whether petitioner is              
          liable for an addition to tax under section 6654 for failure to             
          pay estimated income tax for 1995; and (4) whether we should                
          impose a penalty on petitioner pursuant to section 6673(a).                 
          Background                                                                  
               Some of the facts have been stipulated, and the stipulation            
          of facts and the attached exhibits are incorporated by this                 
          reference.  Petitioner resided in Brazoria, Texas, when he filed            
          his petition.                                                               
               Petitioner did not file a Federal income tax return for the            
          year 1995.  On July 21, 1998, respondent issued a statutory                 
          notice of deficiency to petitioner for the year 1995 based upon             
          taxable income reports issued by third parties.  These reports              
          were that during 1995, petitioner received wages from Belmont               






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