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6651(a)(1) in the amount of $121.60. At trial, respondent orally
moved for imposition of the penalty under section 6673(a).
The issues for decision are: (1) Whether petitioner is
liable for Federal income taxes on compensation he received from
his employer for services he performed as an employee as well as
for income taxes on interest income; (2) whether petitioner is
liable for the section 6651(a)(1) addition to tax; and (3)
whether petitioner is liable for the section 6673(a) penalty.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner was a
legal resident of Columbus, Ohio.
Petitioner was an employee of Ohio State University at
Columbus, Ohio. He worked in the university's Office of
Environmental Health and Safety in the radiation safety section.
Petitioner's responsibility was to see that the various
laboratories on the campus of Ohio State University adhered to
Federal and State regulations affecting the use of radioactive
material. Petitioner had done this work for 10 years at the time
of trial. Prior to that, petitioner was a student at Ohio State
University and had worked part time in the Office of
Environmental Health and Safety for 2 years. Petitioner has a
bachelor's degree in physics.
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