Paula M. Olsen - Page 2

                                        - 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