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(2) whether petitioner is liable for additions to tax under
section 6651(a)(1) for failure to file Federal income tax
returns;
(3) whether petitioner is liable for additions to tax under
section 6654(a) for failure to pay estimated taxes; and
(4) whether the Court should impose a penalty under section
6673.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and supplemental stipulation of facts
are incorporated herein by this reference. Petitioner resided in
Woodinville, Washington, when the petition was filed in this
case.
Capital Gain on Sale of Real Property
In 1996, petitioner sold real estate located at 1018 Market
Street, Kirkland, Washington (hereinafter, the Market Street
property), and 2033 Rose Point Lane, Kirkland, Washington
(hereinafter, the Rose Point Lane property). In 1999, petitioner
also sold real property located at 16103 167th Avenue Northeast,
Woodinville, Washington (hereinafter, the Hollywood Hill lot).
On November 20, 2003,3 petitioner met with Appeals Officer
Jeffrey Sherrill and produced documentation establishing: (1)
3The notices of deficiency were mailed to petitioner on Mar.
26, 2003.
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