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