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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. 6651(a)(2) Sec. 6654
1996 $68,588 $15,087 $16,763 $3,559
1997 21,422 4,708 5,231 1,124
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, interest income, capital gains, and
dividend income. Respondent also determined additions to tax for
failure to timely file, failure to pay, and failure to make
estimated tax payments.
On May 25, 2000, petitioner invoked the jurisdiction of this
Court by timely filing a petition. At the time he filed the
petition, petitioner resided in Big Sandy, Texas.
In the petition, petitioner averred that respondent had
failed to offer a complete, proper, and timely response to his
correspondence, failed to provide documents showing petitioner
“is made liable for any ‘Tax return’”, and failed to correctly
compute the deficiency. Respondent, in the answer, denied the
assignment of errors alleged by petitioner.
On December 18, 2000, in response to respondent’s request,
petitioner attended a conference with respondent. During this
conference, petitioner made it clear that he was aware that the
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