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Additions to tax
Year Deficiency Sec. 6651 Sec. 6654
1993 $2,441 $507 $83.05
1994 1,894 126.75 18.31
1995 4,808 852.50 176.50
1996 8,307 1,732.75 360.76
1997 2,786 364 69.99
The issues for decision are:
1. Whether petitioner bears the burden of proof as to
respondent’s deficiency determinations. We hold that he does.
2. Whether petitioner had unreported income of $21,733 in
1993, $18,252 in 1994, $32,014 in 1995, $44,866 in 1996, and
$24,650 in 1997. We hold that he did, except we hold that he had
unreported income of $17,430 in 1993.
3. Whether petitioner is liable for the additions to tax
for failure to file income tax returns and failure to pay
estimated tax for the years in issue. We hold that he is.
Unless otherwise specified, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
A. Petitioner
Petitioner resided in Glyndon, Maryland, when he filed his
petition in this case. Petitioner retired in 1986.
B. Petitioner’s Income
Petitioner received the following amounts of pension income
during the years in issue:
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