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Respondent issued two separate notices of deficiency for
taxable years 1998 and 1999, respectively. Respondent determined
deficiencies in petitioner's Federal income taxes and additions
to tax in the following amounts:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1998 $1,530 $382.50 -
1999 2,122 530.50 $102.70
This Court must decide: (1) Whether petitioner has
unreported taxable income for 1998 and 1999; (2) whether
petitioner is liable for section 6651(a)(1) additions to tax for
failure to file Federal income tax returns for 1998 and 1999; and
(3) whether petitioner is liable for the section 6654(a) addition
to tax for failure to pay estimated income tax for 1999.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Las Vegas, Nevada, at the time
he filed his petition.
During the taxable years in issue, petitioner received the
following payments in the following amounts:
1998
Nonemployee compensation $ 1,562
Rent 13,523
Interest 21
$15,106
1999
Nonemployee compensation $ 5,224
Rent 10,725
Interest 13
$15,962
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Last modified: May 25, 2011