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the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
In separate notices of deficiency, respondent determined
that petitioner is liable for the following deficiencies in
Federal income taxes and additions to tax:
Docket No. 15732-03S
Addition to Tax
Taxable Year Deficiency Sec. 6651(a)(1)
2001 $2,876 $539.25
Docket No. 10326-04S
Additions to Tax
Taxable Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
2002 $4,048 $1,153.68 $135.27
After concessions,1 the issues for decision are: (1)
Whether petitioner had unreported wage income of $24,036 and
$25,732 from Wal-Mart Associates, Inc., for taxable years 2001
and 2002, respectively; (2) whether petitioner had unreported
wage income of $1,815 for taxable year 2001 from National
Restaurant Enterprises, Inc., also known as Ameriking; (3)
whether petitioner is liable for the additions to tax under
section 6651(a)(1) for failure to file his income tax returns for
1At trial, respondent conceded that the unreported income
from real estate sales of $10,500, which was determined in the
notice of deficiency for taxable year 2002, does not need to be
reported because petitioner actually suffered a loss on the sale
of the property.
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Last modified: May 25, 2011