-3-
Taxable Year
1994 1995 1996 1997
Wage income--U.S. $45,546.33 $36,170.40 $39,020.91 $45,207.89
Postal Service
Wage income--Baltimore Area 900.00 900.00 1,000.00 1,000.00
Local APWU
Interest income--U.S. 20.00 28.00 24.00 -0-
Postal Service Credit Union
Petitioner stipulated that he failed to file Federal income
tax returns and failed to make estimated tax payments for the
taxable years 1994 to 1997, inclusive.
The Court will treat the stipulations as concessions by the
parties resolving the issues of unreported wage income and
interest received for each of the taxable years at issue and the
issues relating to the additions to taxes pursuant to sections
6651(a)(1) and 6654.
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts, and
the exhibits are incorporated herein by this reference. At the
time of the filing of the petition, petitioner resided in
Finksburg, Maryland.
Petitioner has been employed by the U.S. Postal Service in
the main post office in Baltimore for more than 12 years,
including the taxable years in issue.
Gross income includes all income from whatever source
derived. Sec. 61(a). Section 61(a)(5) specifically includes
income derived from rents.
During the taxable years in issue, petitioner owned
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