- 2 - 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”.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011