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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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Last modified: May 25, 2011