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Unless otherwise indicated, all section references are to
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.
Petitioner petitioned the Court to redetermine the
deficiencies and additions to tax.1 We must decide whether: (1)
Petitioner had unreported income in the amounts determined by
respondent for 1998, 1999, 2000, and 2001; (2) petitioner is
liable for the section 6651(a) addition to tax for 1998, 1999,
2000, and 2001; (3) petitioner is liable for the section 6654(a)
addition to tax for 1998, 1999, and 2000; and (4) whether to
impose a penalty pursuant to section 6673(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. At the time he filed the
petition, petitioner resided in Oakland, California.
Petitioner did not file tax returns for 1998, 1999, 2000,
and 2001. Petitioner received total income of $38,863, $42,486,
$23,806, and $16,830, in 1998, 1999, 2000, and 2001,
respectively. Respondent received information from third parties
1 Petitioner also alleged that the deficiencies/liabilities
determined by respondent are excise taxes.
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