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Respondent determined deficiencies in petitioner’s income
taxes and additions to tax for the years and in the amounts as
follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1996 $2,366 $591.50 1 $125.93
1997 2,546 636.50 1 136.19
1Cannot be computed until the date of payment.
The issues for decision are as follows:
(1) Whether petitioner is liable for the deficiencies in
income taxes and additions to tax as determined by respondent in
the notice of deficiency. We hold that he is.
(2) Whether petitioner is liable for a penalty under section
6673(a)(1). We hold that he is.
Background
None of the facts have been stipulated.
Petitioner resided in the State of Iowa at the time that his
petition was filed with the Court.
During 1996 and 1997, the taxable years in issue, petitioner
was employed by Transco Railroad Products, Inc. (Transco) and
received compensation in exchange for services rendered.
Utilizing Form W-2, Wage and Tax Statement, Transco reported
compensation paid to petitioner for the years in issue as
follows:
Year Amount
1996 $22,338
1997 23,749
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