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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011