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$1,055.07 addition to tax pursuant to section 6651(a)(2), and a
$541.37 addition to tax pursuant to section 6654(a).
The issues for decision are: (1) Whether the amount
received by petitioner in 1996 from his employer is taxable; (2)
whether petitioner is liable for an addition to tax for failing
to file a Federal income tax return; (3) whether petitioner is
liable for an addition to tax for failing to pay Federal income
tax; (4) whether petitioner is liable for an addition to tax for
failing to make estimated Federal income tax payments; and (5)
whether petitioner engaged in behavior warranting the imposition
of a penalty pursuant to section 6673(a)(1).
Background
Confronted with petitioner’s refusal to work toward a
stipulation of facts, respondent filed a Motion to Show Cause Why
Proposed Facts and Evidence Should Not Be Accepted As Established
under Rule 91(f) on September 18, 2000. On September 27, 2000,
the Court issued an Order to Show Cause Under Rule 91(f),
requiring petitioner to respond as to why matters set forth in
respondent’s motion should not be deemed admitted. Petitioner
failed to file a response. On November 14, 2000, the Court made
absolute its Order to Show Cause Under Rule 91(f), providing that
the facts and evidence set forth in respondent’s proposed
stipulation of facts were deemed established.
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Last modified: May 25, 2011