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For the taxable years 1996 and 1997, respondent determined
deficiencies in petitioner’s Federal income taxes of $14,622 and
$13,122, additions to tax under section 6651(a)(1) of $3,655.50
and $3,280.50, and additions to tax under section 6654 of $685.08
and $702.05.
The issues for decision are, with respect to taxable years
1996 and 1997: (1) Whether petitioner received unreported income
in the amounts determined by respondent; (2) whether petitioner
is liable for section 6651(a)(1) additions to tax for failure to
file a return; and (3) whether petitioner is liable for section
6654(a) additions to tax for failure to pay estimated Federal
income tax.
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Inman, Kansas, on the date the petition was filed in this case.
During the years in issue, petitioner was doing business as Foos
Boiler Repair.
Petitioner did not file a Federal income tax return for
either of the years 1996 or 1997. Respondent issued petitioner a
statutory notice of deficiency for these years, calculating
petitioner’s tax liability (using the status of married filing
separate returns) as follows:
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