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Respondent determined a deficiency in petitioner’s Federal
income tax and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1996 $9,445 $1,187.55 $1,319.50 $259
After concessions,2 the issues are (1) whether petitioner is
liable for the addition to tax under section 6651(a)(1) for
failure to file a Federal income tax return, (2) whether
petitioner is liable for the addition to tax under section
6654(a) for an underpayment of estimated tax, and (3) whether
this Court has jurisdiction to determine petitioner’s alleged
overpayment of taxes in 1993, 1994, and 1995. Petitioner resided
in New York, New York, at the time the petition was filed.
Background
The facts may be summarized as follows. In 1995, petitioner
was in a car accident and, as a result, suffered physical
injuries. She, however, continued to work and to perform other
responsibilities. Petitioner filed a return for the 1993 taxable
2 Respondent concedes the addition to tax under sec.
6651(a)(2) for failure to pay Federal income tax. Petitioner
concedes the $9,445 deficiency. The Court notes that the amount
of the deficiency is determined without regard to any payment of
estimated tax or credit for tax withheld. Sec. 6211(b)(1). The
tax due by petitioner, after a reduction of $4,167 for tax
payments in 1996 ($3,500 of estimated tax payments and
withholding taxes of $667), is $5,278. In the notice of
deficiency, the additions to tax under secs. 6651(a)(1) and
6654(a) were correctly computed to reflect the $4,167 payment of
tax. See sec. 6651(b)(1).
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