Michael Sawukaytis - Page 2




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               The issues for decision are:  (1) Whether petitioner                   
          received gross income subject to tax, as determined by                      
          respondent; (2) whether petitioner is liable for an addition to             
          tax for failing to file a Federal income tax return for 1996; and           
          (3) whether petitioner engaged in behavior warranting the                   
          imposition of a penalty pursuant to section 6673(a).                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed his            
          petition, petitioner resided in Ann Arbor, Michigan.                        
               During 1996, petitioner was employed at the Ford Motor Co.             
          (Ford).  In 1996, Ford paid petitioner $69,699 in wage income.              
          In 1996, petitioner received a $162 State tax refund for 1995 and           
          $29 of interest from a credit union.                                        
               Petitioner did not file a Federal income tax return for                
          1996.  Pursuant to section 6020(b), respondent prepared a                   
          substitute for return for petitioner.                                       
                                       OPINION                                        
               Section 61 defines gross income as all income from whatever            
          source derived.  Gross income includes compensation for services            
          and interest.  Sec. 61(a)(1), (4).                                          
               Petitioner does not challenge the facts on which                       
          respondent’s determinations are based or respondent’s calculation           






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