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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).
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Last modified: May 25, 2011