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1997. See supra A.
C. Respondent’s Deficiency Notices and Petitioner’s
Response
On June 16, 2000, respondent (acting through Deborah S.
Decker, Director of respondent’s Service Center in Ogden, Utah)
issued separate joint notices of deficiency to petitioner and his
wife for the taxable years 1997 and 1998. In the notices,
respondent determined deficiencies in Federal income taxes, an
addition to tax under section 6651(a)(1) for failure to timely
file, and accuracy-related penalties under section 6662(a) and
(b)(1) for negligence or disregard of rules or regulations, as
follows:
Accuracy-related
Addition to Tax Penalty
Year Deficiency1 Sec. 6651(a)(1) Sec. 6662(a), (b)(1)
1997 $4,699 $117.85 $471.40
1998 2,792 ––- 533.60
1Insofar as their ultimate tax liabilities were concerned, respondent
gave petitioner and his wife credit for the amounts withheld from wages.
However, we note that the determination of a statutory deficiency does not
take such withheld amounts into account. See sec. 6211(b)(1).
The deficiency in income tax for 1997 was based on
respondent’s determination that petitioner and his wife failed to
report income in the aggregate amount of $43,536, consisting of
wages in the amounts of $24,464, $717, and $18,355. See supra A.
The deficiency in income tax for 1998 was based on
respondent’s determination that petitioner and his wife failed to
report income in the aggregate amount of $29,119, consisting of
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