Brian G. Takaba - Page 3




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          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                 





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