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In four separate notices of deficiency, respondent
determined deficiencies in petitioner's Federal income taxes and
additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1997 $3,839 $488.25 –-
1998 4,674 569.50 –-
1999 3,971 974.25 $188.20
2000 5,319 1,329.75 284.10
The issues for decision are: (1) Whether petitioner had
unreported income in the amounts respondent determined, (2)
whether petitioner is liable for additions to tax under section
6651(a)(1) for failure to file timely Federal income tax returns
for taxable years 1997 through 2000, and (3) whether petitioner
is liable for additions to tax under section 6654(a) for failure
to pay estimated income taxes.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioner
resided in Hopkinton, Massachusetts, at the time the petition was
filed.
Respondent obtained copies of Forms W-2, Wage and Tax
Statement, issued by Non Stop Sales & Service, Inc., which show
that petitioner was paid $9,720, $9,940, $3,375, and $2,025 for
tax years 1997, 1998, 1999, and 2000, respectively. Petitioner
stipulated that he received $19,671 and $16,130 from Electronic
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