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(3) whether petitioner is liable for the section 6654
addition to tax for failure to pay estimated tax for 2000.
Background
During the taxable year 1999, petitioner received $18,521 in
wages from University Medical Center Corp. and $8,122 in
nonemployee compensation from Southwest Sleep Diagnostics.
During the taxable year 2000, petitioner received wages of
$16,719 from University Medical Center Corp. and nonemployee
compensation of $17,181 from American Sleep Diagnostics.
Petitioner did not file a Federal income tax return for 1999 or
2000.
On September 12, 2003, respondent issued the underlying
notices of deficiency referenced above. The determined
deficiencies and additions to tax were computed on the basis of
information returns submitted to the Internal Revenue Service by
third-party entities.
Petitioner’s petition challenging the notices of deficiency
was filed with the Court on December 18, 2003, having been
postmarked December 11, 2003, and reflected an address for
petitioner in Tucson, Arizona. The petition reflected
petitioner’s position that his income, being “domestic” and not
from any taxable source identified by regulations, did not
constitute taxable income. Respondent’s answer was filed on
February 4, 2004, and petitioner filed a reply, with multiple
attachments, on March 22, 2004. The attachments set forth at
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