David H. Kilson, Jr. - Page 3

                                        - 2 -                                         
               Respondent determined a deficiency and additions to tax in             
          petitioner’s 1996 Federal income tax as follows:                            
                                             Additions to Tax1                        
               Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)           
               1996  $16,310      $3,046          $3,249         $704                 
               1 The following figures are rounded to the nearest dollar.             
               After concessions,2 the issues are whether petitioner is (1)           
          liable for the addition to tax under section 6651(a)(1) for                 
          failure to file a Federal income tax return, and (2) liable for             
          the addition to tax under section 6654(a) for an underpayment of            
          estimated tax.  Petitioner resided in Philadelphia, Pennsylvania,           
          at the time the petition was filed.                                         
                                     Background                                       
               From 1995 until 1998, petitioner was employed as a “wagon              
          master” for Visionquest National, Ltd., and Visionquest                     
          Lodgemakers.  Petitioner’s duties included supervising troubled             
          youths on the “wagon train”, a group of wagons pulled by mules              
          that travels in many States along the east coast.                           
               In 1995, petitioner’s mother became ill and had surgery.  In           
          July of 1996, petitioner’s mother died.  Petitioner temporarily             
          left the wagon train to attend the funeral.  Petitioner’s father            


          2   In a stipulation of settled issues the parties agreed to a              
          reduced deficiency of $15,541, and respondent conceded the                  
          addition to tax under sec. 6651(a)(2).  As a result of the                  
          reduced deficiency, the additions to tax under secs. 6651(a)(1)             
          and 6654(a) were reduced to $2,873 and $663, respectively.                  





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