Brian Hilvety - Page 2

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                            Additions to tax                                          
           Year Deficiency  Sec. 6651(a)(1)2 Sec. 6651(a)(2)   Sec. 6654(a)           
           1997   $3,088       $694.35           $570.91         $166.23              
               The issues remaining for decision are:3                                
               (1)  Does petitioner have unreported wage income for his               
          taxable year 1997?  We hold that he does.                                   
               (2)  Is petitioner liable for his taxable year 1997 for an             
          addition to tax under section 6651(a)(1)?  We hold that he is.              
               (3)  Is petitioner liable for his taxable year 1997 for an             
          addition to tax under section 6654(a)?  We hold that he is.                 
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
               Petitioner had a mailing address in Moweaqua, Illinois, at             
          the time he filed the petition.                                             
               During 1997, R.W.P. Enterprises, Inc., d/b/a Rat’s Whole               
          Place, paid petitioner wages of $11,130.  That company withheld             
          from those wages FICA tax and Medicare tax of $690 and $161,                
          respectively.                                                               
               During 1997, Trading Specialties International, Inc., paid             
          petitioner wages of $15,522.  That company withheld from those              


               2All section references are to the Internal Revenue Code in            
          effect for the year at issue.  All Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
               3Respondent concedes that petitioner is not liable for his             
          taxable year 1997 for an addition to tax under sec. 6651(a)(2).             
          Respondent conceded in the parties’ stipulation of facts that               
          petitioner had prepaid credits in excess of those determined in             
          the notice of deficiency (notice) issued to him for that year.              




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