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accuracy-related penalties under section 6662(a)1 of $421.80,
$36.60, and $929.20, for 1995, 1996, and 1997, respectively.
The issues for decision are: (1) Whether petitioner is
subject to Federal income tax on wages, Social Security payments,
and IRA distributions; and (2) whether part of the underpayments
of tax is attributable to negligence or disregard of rules or
regulations, or to a substantial understatement of tax.
Background
Petitioner resided in Magna, Utah, when he filed his
petitions in these consolidated cases.
Petitioner filed timely Federal income tax returns for 1995,
1996, and 1997. Petitioner attached to his returns the
appropriate Forms W-2, 1099-R, and 1099. Petitioner failed to
compute an income tax liability on any of the returns but did
attach to each of the returns for 1995 and 1996 a letter of
explanation.
In both letters petitioner states that he needs additional
information to determine his Federal income tax liability: (1)
The sum of the adjusted gross incomes less penalties on early
withdrawal of all income tax filers; (2) the total number of
income tax filers; (3) the total amount of taxes to be collected;
and (4) the names, addresses, and Social Security numbers of
1Unless otherwise indicated, subsequent references are to
the Internal Revenue Code in effect for the years at issue.
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Last modified: May 25, 2011