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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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Last modified: May 25, 2011