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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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Last modified: May 25, 2011