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seven thousand, three hundred and twenty-
three dollars, ($37,323), in wages.
B. The Commissioner has erroneously
alleged that the petitioner received a
capital gain of sixty thousand, six hundred
and twenty-eight dollars, ($60,628).
* * * * * * *
D. The Commissioner has erroneously
alleged that the petitioner owes a
delinquency penalty of three thousand, four
hundred ninety-eight dollars and fifty cents,
($3,498.50), pursuant to Internal Revenue
Code Sec. 6651(a)(1).
E. The Commissioner has erroneously
alleged that petitioner owes a penalty of six
hundred seventy-one dollars and thirteen
cents, ($671.13), for failure to file
quarterly estimates pursuant to Internal
Revenue Code Sec. 6654.
Further, petitioner alleges:
5. The facts upon which petitioner relies, as the
basis of the petitioner’s case, are as follows:
A. To the best of petitioner’s
information, knowledge, and belief, the
petitioner’s total income was less than
twenty thousand dollars, ($20,000). This
compensation consisted of approximately
eleven, (11), days of regular wages with the
remaining compensation deriving from the
exercise of Incentive Stock Option(s).
Petitioner is without documentation
sufficient to produce a more detailed
analysis of said compensation.
* * * * * * *
C. The petitioner’s failure to file
federal income tax returns in a timely manner
is not due to or resultant from willful
neglect.
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