Katrina L. Price - Page 2




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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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