2
Respondent issued petitioner a notice of deficiency in the
amount of $4,167 for taxable year 2001. In the same notice,
respondent determined the following additions to tax:
Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)(2)
$937 $562 $164
After concessions,1 the sole issues for decision are whether
petitioner is liable for additions to tax under sections
6651(a)(1) and 6654(a). We hold that he is.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference.
At the time the underlying petition was filed, petitioner
resided in Clifton, Texas.
During the taxable year at issue, 2001, and the previous
taxable year, 2000, petitioner worked as a corporate trainer for
Compliance Systems, Inc. (Compliance). Under the terms of his
employment, Compliance provided petitioner with materials
necessary for him to lead hazardous materials training courses
for its employees.
A dispute arose between petitioner and Compliance sometime
in late 2001 regarding petitioner’s employment status. Although
1 Respondent has conceded the addition to tax under sec.
6651(a)(2) for failure to pay. Petitioner conceded that he
received wages of $17,588 and interest income of $11.
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