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Additions to Tax Penalties
Year Deficiency Sec. 6651(a)(1) Sec. 6662
1996 $2,617 $750 $523
1997 6,292 1,605 1,258
2000 5,723 --- 837
The issues for decision are: (1) Whether petitioner is
liable for the deficiencies respondent determined in the notices
of deficiency for 1996, 1997, and 2000 (years in issue); (2)
whether petitioner is liable for additions to tax for failing to
timely file his Federal income tax returns (tax returns) under
section 6651(a)(1)2 for 1996 and 1997; (3) whether petitioner is
liable for accuracy-related penalties under section 6662 for the
years in issue; and (4) whether petitioner engaged in behavior
warranting the imposition of a penalty under section 6673.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petitions, petitioner resided in Chicago, Illinois.
On May 28, 1999, respondent received from petitioner tax
returns for 1996 and 1997 signed by petitioner and purportedly
signed by Lori Israel, petitioner’s former spouse, reporting
wages received by petitioner from the U.S. Postal Service.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. Amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011