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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1996 $4,195 $1,009 $214
1997 4,377 993 210
1998 3,908 977 179
The issues for decision are: (1) Whether petitioner received
unreported interest income as determined in the notices of
deficiency, and (2) whether petitioner is liable for additions to
tax pursuant to sections 6651(a)(1) and 6654 for the years at
issue.
Background
When he petitioned this Court, petitioner resided in
Oklahoma City, Oklahoma.
For each year at issue, petitioner received interest income
from numerous financial institutions. The interest income
totaled $39,648, $36,859, and $32,683 for 1996, 1997, and 1998,
respectively.2
Petitioner filed no Federal income tax return for 1996 or
1997. On May 7, 1999, the Internal Revenue Service received from
petitioner a Form 1040, U.S. Individual Income Tax Return, for
his 1998 tax year. This document (the purported 1998 return)
1(...continued)
(RRA 1998), Pub. L. 105-206, sec. 3001, 112 Stat. 726). Rule
references are to the Tax Court Rules of Practice and Procedure.
2 Petitioner admits in his petition that he received those
amounts of interest income.
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Last modified: May 25, 2011