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Respondent determined for 2001 a deficiency in petitioner's
Federal income tax of $24,702 and additions to tax of $5,557.95
under section 6651(a)(1), an uncomputed amount under section
6651(a)(2), and $977.53 under section 6654(a).
The parties agree that petitioner: (a) Received wages of
$99,522 and unemployment compensation of $6,468, (b) is entitled
to a filing status of single and to claim one personal exemption,
(c) is entitled to deduct property taxes paid to the Harris
County Tax Assessor and the Houston Independent School District
in the amounts of $3,039.46 and $3,102, (d) is entitled to
deduct, as a charitable contribution, a $185 donation to the Rice
University Owl Club, and (e) is not liable for the addition to
tax provided by section 6651(a)(2).
The issues for decision are whether petitioner: (1) Is
entitled to claim itemized deductions and business losses in
excess of those allowed by respondent, (2) is liable for the
addition to tax under section 6651(a)(1) for failure to file
timely a Federal income tax return for the year without
reasonable cause, and (3) is liable for the addition to tax under
section 6654 for failure to pay estimated tax.
The exhibits received into evidence are incorporated herein
by reference. At the time the petition was filed, petitioner
resided in Houston, Texas.
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