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addition to tax under section 6651(a)(1) in the amount of $440.
The deficiencies in income tax were based on respondent’s
determination that petitioner failed to report wage income,
unemployment compensation, and tip income.
On July 6, 1998, respondent received a letter (postmarked
June 26, 1998) from petitioner acknowledging receipt of the
notices of deficiency dated May 4, 1998, and challenging their
validity. Petitioner did not file a petition for redetermination
with the Court challenging the notices of deficiency dated May 4,
1998.
On September 11, 1998, respondent issued two joint notices
of deficiency to petitioners. In the first notice, respondent
determined a deficiency in the amount of $4,984 in petitioners’
Federal income tax for 1995 and an accuracy-related penalty under
section 6662(a) in the amount of $871. In the second notice,
respondent determined a deficiency in the amount of $8,030 in
petitioners’ Federal income tax for 1996 and an accuracy-related
penalty under section 6662(a) in the amount of $1,346. The
deficiencies in income tax were based on respondent’s
determination that petitioners failed to report wage income (1995
and 1996), unemployment compensation (1995), and a distribution
from an IRA (1996).
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