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Respondent determined the following deficiency in and
additions to petitioner’s 1997 Federal income tax:
Additions to Tax
Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
$9,296 $1,998.22 $1,598.58 $475.95
After a concession by respondent,1 the issues for decision are:
(1) Whether petitioner’s wages, nonemployee compensation, prizes
and awards, interest, and distribution from an individual
retirement account (IRA) received during 1997 constitute gross
income; (2) whether petitioner is liable for an addition to tax
for failing to file a 1997 Federal income tax return; and (3)
whether petitioner is liable for an addition to tax for failing
to pay estimated income tax.
Some of the facts have been stipulated and are so found.
Petitioner resided in Santa Clara, California, at the time the
amended petition was filed with the Court.
Petitioner has a bachelor of science degree in electrical
engineering from the University of Washington and a master of
science degree in computer science from the University of Santa
Clara. Petitioner has been employed for many years as a computer
programmer.
1Respondent concedes that petitioner is not liable for an
addition to tax under sec. 6651(a)(2).
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Last modified: May 25, 2011