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Respondent determined the following deficiencies in and
additions to petitioner’s Federal income taxes for 1995, 1996,
and 1997:
Additions to Tax Under Sections
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
1995 $4,856 $610 -- $118
1996 6,978 758 $843 158
1997 10,243 1,047 1,163 216
After concessions,1 the issues for decision are: (1) Whether
respondent’s period of limitations within which to assess the
1995, 1996, and 1997 Federal income taxes against Georges Z.
Zakhem (petitioner) has expired; and (2) if not, whether
petitioner is liable for additions to tax under sections
6651(a)(1) and 6654.
Background
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioner resided in Boulder, Colorado.
During the taxable years at issue, petitioner was employed
by Exabyte Corporation (Exabyte) in Boulder, Colorado. For the
years 1995, 1996, and 1997, Exabyte issued Forms W-2, Wage and
Tax Statement, to petitioner which incorrectly reported
petitioner’s Social Security number by one digit. By letter
1Respondent concedes that the addition to tax under sec.
6654 asserted in the notice of deficiency for 1995 and the
additions to tax under sec. 6651(a)(2) asserted in the notices of
deficiency for 1996 and 1997 do not apply to this case.
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