- 3 - an addition to tax under section 6654(a)? We hold that he is. Background Some of the facts have been deemed established pursuant to the Court’s Order under Rule 91(f) dated March 13, 2003. In addition, the record establishes and/or the parties do not dispute the following.3 At the time he filed the petition in this case, petitioner’s address was in Morton Grove, Illinois. During 1996 and 1997, petitioner was engaged in a washing machine repair business from which he had net profit of $30,200.31 and $30,227.02, respectively. On April 18, 1996, respondent received from petitioner an estimated tax payment for 1996 in the amount of $2,000. On April 17, 1997, respondent received from petitioner a payment of $25,624 with respect to his taxable year 1996 and a document dated April 12, 1997 (petitioner’s document for 1996). Respondent did not receive from petitioner any tax return or other document pertaining to his taxable year 1997. Petitioner’s document for 1996 consisted of Form 1040, U.S. Individual Income Tax Return (Form 1040), for 1996 from which petitioner had stricken much of the preprinted language, includ- ing the declaration that appeared above the place for the tax- 3At trial, the parties called no witnesses, and respondent introduced into the record certain exhibits.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011