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Petitioner, a Philadelphia police officer, failed to file
timely a Federal income tax return for taxable year 2000.
Respondent determined petitioner's income on the basis of
information returns submitted to respondent by third party
payors. Respondent also determined that petitioner is liable for
the above-listed additions to tax.
On March 19, 2004, after respondent issued petitioner a
statutory notice of deficiency, petitioner submitted a tax return
for 2000 (March return). Respondent has not processed the March
return, and no tax has been assessed as a result of petitioner's
submission of the March return.
After the petition was filed, respondent filed an answer
conceding that petitioner is not liable for an addition to tax
under section 6651(a)(2) and asserting an increase in the
addition to tax under section 6651(a)(1) of $157.35.
At trial, petitioner submitted an additional tax return he
referred to as an "amended return" for taxable year 2000.
A. Petitioner's Income for the 2000 Taxable Year
1. Wages
In 2000, petitioner received wages of $6,275 from Society
Hill Towers. He also received wages of $66,935 from the City of
Philadelphia. Federal income tax of $10,289 was withheld from
petitioner's wages.
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