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determined the following deficiencies in and additions to
petitioner’s Federal income taxes:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1994 $27,797 $2,113.25 $327.11
1995 89,992 17,451.00 3,663.33
1996 28,908 2,666.25 459.75
Background
In the notices of deficiency, respondent determined, on the
basis of income reported by third-party payers, that petitioner
failed to report wage income, capital gains, interest income, and
dividend income. Respondent also determined additions to tax for
failure to timely file returns and failure to make estimated tax
payments.
On June 28, 1999, petitioner invoked the jurisdiction of
this Court by timely filing an imperfect petition. On July 1,
1999, the Court ordered petitioner to file an amended petition in
order to comply with the Rules of the Court as to the form and
content of a proper petition and enclosed the form with the
order. On September 3, 1999, petitioner filed the amended
petition on the form enclosed with the Court’s July 1, 1999,
order. At the time he filed the amended petition, petitioner
resided in Pepper Pike, Ohio.
In the petitions, petitioner averred, among other things,
that respondent’s determinations were erroneous “based upon the
actual capital gain calculation versus the use of gross proceeds
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