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]Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011