Joseph T. Tornichio - Page 3




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          his Fifth Amendment rights; and that his wages do not constitute            
          “income” within the meaning of the Internal Revenue Code, on the            
          basis of his interpretation of the “Corporation Excise Tax Act              
          (of 1909)” and on a theory that only corporate-derived income               
          constitutes taxable income.                                                 
          B.  Notices of Deficiency and Petitioner’s Responses                        
               On October 10, 1997, and February 6, 1998, respondent                  
          (acting through Jimmy L. Smith, Director of the Internal Revenue            
          Service (IRS) Service Center in Cincinnati, Ohio) issued                    
          petitioner notices of deficiency for 1995 and 1996, respectively;           
          and on May 28, 1999, respondent (acting through R. Wayne Hicks,             
          Director of the IRS Service Center in Cincinnati, Ohio) issued              
          petitioner a notice of deficiency for 1997.  In these notices,              
          respondent determined deficiencies in, and additions to,                    
          petitioner’s Federal income taxes as follows:                               
                                                  Additions to Tax                    
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6654(a)              
               1995      $8,826         $1,788.00           $324.00                   
               1996      11,990         2,857.55            605.09                    
               1997      20,465         5,058.25            1,081.10                  
               The deficiencies were based on respondent’s determination              
          that petitioner failed to report wage income as reported to                 
          respondent by Nationwide Communications, Inc., on Forms W-2, Wage           
          and Tax Statement.                                                          









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