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Additions to Tax, I.R.C.
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1995 $2,864 $716.00 $155.29
1996 2,592 648.00 137.96
1997 2,737 684.25 146.43
1998 3,666 916.50 167.75
The only bona fide issue for decision is whether a penalty
should be imposed on petitioner under section 6673.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
The relevant facts have been deemed stipulated pursuant to
Rule 91(f). Petitioner resided in Tempe, Arizona, at the time he
filed his petition.
During the years in issue, petitioner was a retired Federal
employee. He received a pension paid by the U.S. Office of
Personnel Management in the amounts of $19,272, $19,782, $20,484,
and $20,904 for 1995, 1996, 1997, and 1998, respectively.
During the years in issue, petitioner also received payments
as follows:
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Last modified: May 25, 2011