- 2 -
dent’s motion for summary judgment (respondent’s motion).2 We
shall grant respondent’s motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Euless, Texas, at the time he filed
the petition in this case.
Petitioner did not file a Federal income tax (tax) return
for any of his taxable years 1992, 1993, and 1994. Respondent
prepared a substitute for return for each such year.
On March 17, 1999, respondent issued to petitioner a notice
of deficiency (notice) with respect to his taxable years 1992,
1993, and 1994, which he received. In that notice, respondent
determined a deficiency in, and an addition to, petitioner’s tax
for each such year, as follows:
Addition to Tax
Year Deficiency Under Sec. 6651(a)(1)3
1992 $1,369 $108
1993 1,369 312
1994 994 223
Petitioner did not file a petition with the Court with
respect to the notice relating to his taxable years 1992, 1993,
2Although the Court ordered petitioner to file a response to
respondent’s motion, petitioner failed to do so.
3All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011