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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.
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