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Respondent determined the following deficiencies and
additions to tax with respect to petitioner’s Federal income
taxes:
Additions to Tax
Taxable Year Deficiency Sec. 6651(a)(1) Sec. 6654
1994 $11,118 $2,736.25 $566.94
1995 8,322 2,068.50 448.32
1996 9,203 1,721.50 352.78
1997 10,909 2,360.75 496.50
After concessions, which are discussed below, the issues to
be decided involve the correct amount of rental income for each
taxable year at issue and the amount of allowable expense
deductions. Petitioner failed to file Federal income tax returns
and failed to make estimated tax payments for the taxable years
1994 to 1997, inclusive. As a result, respondent prepared
substitute returns for each of the taxable years in issue, and in
the notice of deficiency made the following adjustments:
Taxable Year
1994 1995 1996 1997
Wage income received $48,857 $39,543 $43,045 $49,610
Interest income 20 28 24 --
Rental income 5,000 5,000 5,000 5,000
Respondent computed the above deficiencies allowing
petitioner the standard deduction and one exemption and using the
tax table for married individuals filing separately.
The parties stipulated that petitioner received income
during each of the taxable years as follows:
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