- 2 - Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1994 $3,361 $ 616 $123 1995 4,738 1,080 232 1996 1,504 331 --- The issues for decision are: (1) Whether petitioner, under section 61, is liable for Federal income taxes on income of $26,457, $31,759, and $15,937, respectively, for 1994, 1995, and 1996; (2) if so, whether petitioner is entitled to itemized deductions in excess of amounts conceded by respondent at trial; and (3) whether petitioner is liable for the additions to tax shown above.2 Some of the facts were stipulated, and those facts, with the annexed exhibits, are so found and are incorporated herein by reference. At the time the petition was filed, petitioner's legal residence was Salt Lake City, Utah. Petitioner did not file a Form 1040, U.S. Individual Income Tax Return, for the years at issue. In lieu of a return, for the 2 At trial, respondent conceded that petitioner's filing status was single rather than married filing separately as determined in the notice of deficiency, the effect of which reduces the deficiencies and additions to tax. In addition, the notice of deficiency allowed petitioner the standard deduction under sec. 63 in lieu of itemized deductions for each of the years at issue. At trial, respondent conceded petitioner's entitlement to itemized deductions for the years 1994 and 1995. As to this issue, the question is petitioner's entitlement to itemized deductions in excess of the amounts conceded by respondent. A decision will be necessary under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011