- 3 -
petitioner and costs under section 6673(a)(2) should not be
imposed on Mr. Sulla. Petitioner and Mr. Sulla appeared and were
heard in response to the orders to show cause at the trial
session of the Court commencing on June 18, 2001, in Honolulu,
Hawaii (the 2001 trial session). Due in part to the length of
Mr. Sulla’s argument, the Court ordered additional submissions
with respect to its orders to show cause.
June 6 Order
The following is extracted or summarized from the June 6
order and is helpful to explain our imposition of a penalty and
costs.
By notice of deficiency dated December 21, 1998 (the
notice), respondent determined a deficiency of $3,407 in
petitioner’s 1996 income tax and additions to tax of $669.52,
$295.35, and $165.64 under sections 6651(a)(1) (failure to file a
return), 6651(a)(2) (failure to pay tax), and 6654(a) (failure to
pay estimated tax), respectively.
The facts that we relied on in granting the motion for
summary judgment are as follows:
During 1996, petitioner was employed by Thunderbug,
Inc. (Thunderbug), a domestic (United States)
corporation doing business as Magnum Motorsport.
During 1996, petitioner received remuneration in the
amount of $29,251 from Thunderbug as compensation for
labor or services performed by petitioner in the United
States. Petitioner also received interest in 1996 from
American Savings Bank in the amount of $13. Petitioner
failed to file a U.S. Income tax return for 1996.
Petitioner did not make any estimated tax payments for
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011