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Respondent determined a deficiency, an accuracy-related
penalty under section 6662(a),1 and an addition to tax for
failure to pay estimated taxes under section 6654(a) in
petitioner’s 1998 Federal income tax in the respective amounts of
$31,070, $6,214 and $1,086.
Petitioner was a resident of San Jose, California, at the
time he filed his petition.
Petitioner was employed by the Quicksilver Group, a software
consulting company, throughout 1998. Petitioner admits that in
1998 he received wages of $105,873, interest of $294, and an
early distribution from his individual retirement account of
$13,291. Petitioner also admits that no Federal income tax was
withheld from his wages and that he made no estimated tax
payments or other payments on account of his income for 1998.
Petitioner’s employer filed with respondent a Form W-2, Wage
and Tax Statement, showing that it had paid petitioner “wages,
tips, other compensation” of $105,873. The interest and the
early distribution from petitioner’s individual retirement
account were reported to respondent by the payors on Form 1099s.
Petitioner demanded that his employer file an amended Form
W-2 stating that he had received no wages, tips, or other
compensation. When petitioner’s employer refused to amend the
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue.
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