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regard to petitioner’s 2000 Federal income tax. After
concessions,3 the issues for decision are: (1) Whether
petitioner is entitled to a loss carryover; (2) whether
petitioner is entitled to itemized deductions for State income
tax payments and unreimbursed employee expenses; (3) whether
petitioner is liable for an addition to tax pursuant to section
6651(a)(1); and (4) whether petitioner is liable for an addition
to tax pursuant to section 6654(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Palo Alto, California, at the time she filed her petition.
Petitioner’s Returns
During 2000, petitioner was an employee of Phoenix
Technologies, Inc. (Phoenix). Petitioner was paid $193,099 by
Phoenix and had $1,235 of Federal income tax withheld by Phoenix.
Petitioner also received $14,996 from the sale of Insilicon
stock. Petitioner did not make estimated tax payments for 2000.
Petitioner did not file a Form 1040, U.S. Individual Income
Tax Return, for the taxable years 1998, 1999, and 2000.
Petitioner submitted to the Court an unfiled Form 1040 for
3 Respondent conceded the sec. 6651(a)(2) addition to tax.
Respondent also conceded that petitioner is entitled to a $14,513
deduction for State income taxes.
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