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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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