- 2 - 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 calculationPage: Previous 1 2 3 4 5 6 Next
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