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2. Held, further: P has failed to carry his burden of
proving that his tax return for any of the 3 years was filed
less than 4 months and 1 day after the extended due date for
that tax return.
Randall Mark Jacobson, pro se.
Richard A. Stone, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined deficiencies in
individual income tax and additions to tax under sections
6651(a)(1)1 (late filing of tax return) and 6654 (underpayment of
estimated tax) against petitioner as follows:
Additions to Tax
Year Deficiency1 Sec. 6651(a(1) Sec. 6654
1993 $61,611 -- $240
1994 54,821 $4,955 993
1995 64,679 9,295 2,841
1 Of these amounts, $10,279 for 1993, $11,483 for 1994, and
$12,200 for 1995 are self-employment taxes, under ch. 2; the
remaining amounts are ch. 1 income taxes.
After concessions by both sides,2 the issue for decision is
1Unless indicated otherwise, all section and chapter
references are to sections and chapters of the Internal Revenue
Code of 1986 as in effect for the years in issue.
2The parties’ agreements are sufficient to calculate the
amount of petitioner’s and Evalyn V. Jacobson’s joint tax liability
for each year. At the time of the trial, the parties stipulated
that petitioner had a 1993 overpayment of about $41,000, a 1994
overpayment of about $7,000, and a 1995 underpayment of about
$9,000. Respondent concedes the additions to tax for 1993 and
1994.
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