- 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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