6 time. United States v. Boyle, 469 U.S. 241 (1985); sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Petitioner testified that he did not file his Federal income tax return on its original due date because he was awaiting respondent’s determination of his employment status and thereafter, because Compliance did not provide him with a Form W- 2, nor did it report his wages to respondent. Petitioner’s reasoning as to why he did not file his 2001 return is misguided and without merit. Petitioner did not contest that he received gross income for 2001 of $17,588, nor did he dispute his obligation to pay tax on this income and file a return. Further, he did not challenge that his employer withheld no Federal income tax from his compensation for 2001. Secs. 63(a), 6001. Therefore, petitioner’s employment status had no bearing on his obligation under law to file a Federal income tax return. Moreover, if we were to believe petitioner’s claim that he timely filed a request for an extension to file, his return would have been due on October 15, 2002. Since respondent’s determination letter was received on May 10, 2002, petitioner would have had sufficient time to file a return for 2001. Petitioner next claimed that he did not file his return after receiving respondent’s determination letter because Compliance did not file a Form W-2 as requested by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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