- 2 - Addition to tax Addition to tax Taxable Year Deficiency Sec. 6651(a)(1) Sec. 6654 1990 $5,917 $1,479 $387 1994 4,425 939 191 1996 4,093 1,023 218 After concessions,2 the only remaining issues for decision are:3 (1) Whether petitioner received unreported income during 1990, 1994, and 1996 of $25,838, $30,243, and $29,812, respectively; (2) whether petitioner is liable for additions to tax for failure to file Federal income tax returns for 1990, 1994, and 1996; and (3) whether petitioner is liable for additions to tax for failure to make sufficient estimated tax payments in 1990, 1994, and 1996. Some of the facts have been stipulated, and the stipulations are incorporated herein by this reference. Petitioner resided in Lawton, Oklahoma, at the time the petition was filed. During 1990, petitioner received commissions of $17,516, a pension of $3,433, unemployment compensation of $4,065, dividends of $20, and wages of $804. During 1994, petitioner received unemployment compensation of $2,450, dividends of $46, and wages of $27,747. During 1996, petitioner received a pension of 2Petitioner did not dispute, nor did he present evidence regarding, respondent’s determination that petitioner had self- employment income in 1990 of $17,516 and was liable for self- employment tax on that income. This adjustment is deemed conceded in accordance with Rule 34(b)(4). 3The only other issues raised in the notices of deficiency are computational.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011