- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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