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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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