Respondent determined a deficiency in petitioner's Federal
income tax for 1996 of $10,351; and additions to tax under
section 6651(a)(1) of $1,571.85, under section 6651(a)(2) of
$698.60, and under section 6654 of $356.05.
The parties agree that petitioner's income tax deficiency,
without taking into account respondent's assessment of tax
subsequent to the mailing of the notice of deficiency on May 18,
1999, is $6,110, that respondent made an assessment of income tax
on May 29, 2000, of $2,599, and that petitioner's income tax
deficiency to be assessed is $3,511. The parties also agree that
there is no addition to tax due from the petitioner under the
provisions of section 6654.
The issues for decision are whether petitioner filed his
Federal income tax return timely and timely paid his income tax
due for 1996.
Background
Some of the facts have been stipulated and are so found, and
the accompanying exhibits are incorporated herein by reference.
At the time the petition was filed, petitioner resided in
Princeton, New Jersey.
In his petition, with respect to his 1996 Federal income tax
return, petitioner alleges that "extension was file [sic]
including $200 check, return was sent before 8/96". In his trial
memorandum, petitioner alleges that he "filed a timely [1996]
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