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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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Last modified: May 25, 2011