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The issues for decision are: (1) Whether petitioner had a
deficiency for 1999, as determined by respondent; (2) whether
petitioner is liable for an addition to tax for failing to file a
Federal income tax return for 1999; (3) whether petitioner is
liable for an addition to tax for failing to make estimated tax
payments for 1999; and (4) whether petitioner engaged in behavior
warranting the imposition of a penalty pursuant to section
6673(a).
FINDINGS OF FACT
None of the facts have been stipulated. At the time he
filed his petition, petitioner resided in Billings, Montana.
During 1999, petitioner was employed by the Kmart Corp.
(Kmart) in Billings, Montana. In 1999, Kmart paid petitioner
$21,078.12 in wage income. During 1999, Kmart withheld zero
Federal income tax, $1,306.84 of Social Security tax, and $305.63
of Medicare tax. Petitioner made no estimated income tax
payments for 1999.
Petitioner submitted an unsigned Form 1040A, U.S. Individual
Income Tax Return, for 1999 to respondent. Petitioner listed
zero as the amount of his wages, total income, adjusted gross
income, taxable income, and total tax. On the line for
nontaxable income earned petitioner listed “ALL”. Petitioner
claimed a refund of $1,926.12 for amounts withheld for Federal
income tax ($1,612.47) and estimated tax payments ($313.65).
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