T.C. Memo. 2000-62
UNITED STATES TAX COURT
ROBERT J. BIVOLCIC, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18721-98. Filed February 28, 2000.
Robert J. Bivolcic, pro se.
Caroline Ades-Pierri, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: Respondent determined a
deficiency in petitioner's Federal income tax in the amount of
$7,131, an addition to tax under section 6651(a)(1) of $1,198,
and an addition to tax under section 6654 of $239 for the taxable
year 1996. Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the year in issue.
At trial, respondent conceded the section 6651(a)(1)
addition to tax. The Court must decide: (1) Whether wages
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