Anthony Tinsman - Page 2




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          determined additions to tax under section 6651(a)1 for failure by           
          petitioner to file timely his Federal income tax returns in the             
          amounts of $733 for 1994, $292 for 1995, and $295 for 1996.                 
               The issues for decision are:  (1) Whether the notice of                
          deficiency is arbitrary and excessive, and therefore is not                 
          entitled to the presumption of correctness; (2) whether                     
          petitioner received an unreported IRA distribution in 1994; (3)             
          whether petitioner is liable for the additional tax on early                
          distributions from qualified retirement plans; (4) whether                  
          petitioner had unreported income for 1995 and 1996; and (5)                 
          whether petitioner failed to file timely Federal income tax                 
          returns for 1994, 1995, and 1996 without reasonable cause.                  
               The stipulated documents are incorporated herein by                    
          reference.  Petitioner resided in Midland, Arkansas, at the time            
          he filed his petition in this case.                                         
                                     Background                                       
               During the years at issue and at the time of trial,                    
          petitioner was married and had two children.                                
               Petitioner filed a Federal income tax return for 1994 that             
          he signed and dated May 24, 1996.  He attached to the tax return            
          a Form W-2, Wage and Tax Statement, from Petroleum Helicopters,             
          Inc. (Helicopters), reporting wages, tips, and other compensation           


               1  Section references are to the Internal Revenue Code in              
          effect for the years in issue, and Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      




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