Edward T. O'Toole - Page 2




                                        - 2 -                                         
                                        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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