Anthony P. Hart - Page 2




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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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