- 43 - sale of the arcade games.18 Addition to Tax Under Section 6651(a)(1) Respondent determined that petitioner is liable for 1996 for an addition to tax under section 6651(a)(1). The record estab- lishes that petitioner did not file a tax return for 1996. Petitioner claims that he does not have the requisite amount of income that would have required him to file a tax return for that year. The record in the instant case belies that claim. In a stipulation of settled issues filed by the parties on April 16, 2002, petitioner conceded that for 1996 he has $6,178 of income, consisting of $4,000 of income with respect to his employment by Uptime Nutrition and $2,178 of income with respect to unemploy- ment compensation from the Minnesota Department of Economic Security. Based on petitioner’s concessions alone, he was required to file a tax return for 1996.19 See sec. 6012. On the record before us, we find that petitioner has failed to carry his burden of showing that he is not liable for an addition to tax under section 6651(a)(1) for 1996. We have considered all of the contentions and arguments of petitioner that are not discussed herein, and we find them to be 18Petitioner does not contend, and has failed to establish, that he has a basis in the arcade games that he sold to Reality Entertainment. 19In addition to the $6,178 of income that petitioner con- ceded he has for 1996, we have found that petitioner has $115,836.61 of income for that year.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
Last modified: May 25, 2011