Dale I. Dirkes - Page 2




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                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               DINAN, Special Trial Judge:  This matter is before the Court           
          on respondent’s Motion for Summary Judgment filed pursuant to               
          Rule 121(a).  Petitioner filed Petitioner’s Objection to                    
          Respondent’s Motion for Summary Judgment.  As explained below, we           
          will grant respondent’s Motion for Summary Judgment.                        
                                   Background                                         
               On April 7, 1998, respondent mailed a notice of deficiency             
          to petitioner determining a deficiency in his Federal income tax            
          for 1993 of $71,280 and additions to tax pursuant to section                
          6651(a)(1) and section 6654(a) of $13,143 and $2,115.63,                    
          respectively.  Respondent determined that petitioner failed to              
          timely file his income tax return for the year in issue, failed             
          to pay estimated taxes, and failed to report the following                  
          amounts includable in income:                                               
                    Capital gain                     $137,835                         
               Interest                               13                              
                    Prior year refund                     227                         
                    Wages                             103,582                         
          Respondent also determined that petitioner was entitled to a                
          standard deduction of $3,100 and that petitioner’s filing status            
          was “married filing separate return”.                                       











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