- 2 - Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1992 $53,380 $2,757 $275 1993 64,534 4,976 626 1994 64,065 4,727 715 1995 55,566 4,567 772 The issues for decision are: (1) Whether petitioner is subject to Federal income tax on wage income from United Airlines; (2) whether petitioner is liable for additions to tax for failing to timely file Federal income tax returns and for failing to pay estimated taxes; and (3) whether a penalty should be awarded to the United States under section 6673.1 FINDINGS OF FACT Some of the facts have been deemed stipulated2 and are so found. 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2The parties did not have a signed stipulation of facts at trial. Respondent’s proposed stipulation of facts contained facts such as petitioner’s address, copies of unsigned Forms 1040, with attached Forms W-2 from United Airlines, Inc., that petitioner submitted to respondent for the years at issue, and that showed petitioner’s wages from United Airlines during the relevant years. Some of the facts were previously admitted in response to respondent’s request for admissions. At trial, petitioner asserted that the Forms 1040 were irrelevant and then invoked his Fifth Amendment rights about each proposed finding of fact. Based on our review of the entire record, including petitioner’s various filings, we found that there was no legitimate dispute concerning the facts stated in the proposed stipulation of facts, and we granted respondent’s motion to compel stipulation under Rule 91(f).Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011