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The issues for decision are:
1. Whether petitioner is liable for income tax on her
salary of $13,000 per year in 1993 and 1994 and additional income
of $25,500 in 1993 and $5,486 in 1994. We hold that she is.
2. Whether petitioner is liable for additions to tax for
failure to file and failure to pay estimated tax for 1993. We
hold that she is.
3. Whether petitioner is liable for the accuracy-related
penalty for negligence for 1994. We hold that she is.
Section reference are to the Internal Revenue Code in effect
in the years in issue, and Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in New York, New York, when she filed the
petition in this case. She had a savings and checking account at
Citibank and Chemical Bank. She had no other bank accounts
during the years in issue.
Petitioner had $100 or less of cash at the beginning of
1993. She did not receive any gifts, inheritances, or loans in
1993 or 1994, or own any certificates of deposit, stocks, or
bonds in those years.
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