- 2 -
did not raise any bona fide dispute with respect to the amounts
determined by respondent, the only issue for decision is the
appropriate amount of a penalty under section 6673. 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.
FINDINGS OF FACT
Petitioner resided in New York at the time that he filed his
petition. During the years in issue, petitioner was employed by
LSI Logic Corp. Petitioner received wages of $60,796.32 in 2001
and $98,452.38 in 2002 from LSI Logic Corp. Those wages were
reported to the Internal Revenue Service (IRS) on Forms W-2, Wage
and Tax Statement.
During 2002, petitioner received a distribution from Charles
Schwab Trust Co., Trustee, in the amount of $33,112.44. That
distribution was reported to the IRS on Form 1099-R,
Distributions From Pensions, Annuities, Retirement or Profit-
Sharing Plans, IRAs, Insurance Contracts, etc.
Petitioner failed to file Federal income tax returns for
2001 and 2002. Based on reports received from LSI Logic Corp.
and Charles Schwab Trust Co., Trustee, and other third-party
payers, respondent made the determinations set forth in the
notices of deficiency.
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011