Greg Olson - Page 2

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                                 MEMORANDUM OPINION                                   

               WHERRY, Judge:  This case is before the Court on cross-                
          motions by the parties for summary judgment pursuant to Rule                
          121.1   The instant proceeding arises from notices of deficiency            
          in which respondent determined the following deficiencies and               
          additions to tax with respect to petitioner’s Federal income                
                                             Additions to Tax                         
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6654                 
               1999      $4,107         $427.25        --                             
               2000      9,772          1,908.50       $395.08                        
          After a concession by respondent with respect to 2000, the                  
          recalculated amounts for the deficiency, section 6651(a) addition           
          to tax, and section 6654 addition to tax for that year are                  
          $6,921, $1,195.75, and $242.81, respectively.  The issues for               
          decision are:                                                               
               (1) Whether petitioner received taxable income during 1999             
          and 2000, a portion of which is subject to self-employment tax;             
               (2) whether petitioner is liable for the section 6651(a)(1)            
          addition to tax for failure timely to file income tax returns for           
          each of the years at issue; and                                             

               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code of 1986 as amended and in effect for the              
          years in issue, and Rule references are to the Tax Court Rules of           
          Practice and Procedure.                                                     

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