- 3 -
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654
1997 $10,371 $2,592.75 To be determined $459.70
1998 13,521 3,380.25 To be determined 618.69
The issues for decision are: (1) Whether petitioner received
wages, interest, and pension and individual retirement plan
distributions as taxable income in the amounts that respondent
determined; (2) whether petitioner is liable for a 10-percent
additional tax under section 72(t)(1);1 (3) whether petitioner is
liable for additions to tax under sections 6651(a)(1) and (2) and
6654; and (4) whether to impose a penalty under section
6673(a)(1).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the attached exhibits, and the
supplemental stipulation of facts are incorporated herein by this
reference. At the time of filing the petition, petitioner
resided in Brandamore, Pennsylvania.
Petitioner was employed by Environmental Compliance
Services, Inc. (ECS). ECS paid petitioner $47,051.55 in 1997 and
$50,871.48 in 1998 as salary. ECS issued to petitioner Forms W-
2, Wage and Tax Statement, which reflected those amounts as
wages. In 1997, petitioner received $200 in interest from the
1All section references are to the Internal Revenue Code in
effect for the taxable years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011