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Respondent also determined that petitioner is liable for the
addition to tax under section 6651(a)(2)1 for failure to pay tax
shown on the return in amounts to be calculated later for each
year in issue. The issues for decision are:
1. Whether respondent correctly determined petitioner’s
income tax deficiencies for 1998, 1999, and 2001. We hold that
respondent did.
2. Whether petitioner is liable for additions to tax for
failure to file tax returns and for failure to pay estimated tax
for 1998, 1999, and 2001. We hold that he is.
3. Whether petitioner is liable for the addition to tax for
for failure to pay tax. We hold that he is not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in Metairie, Louisiana, when he filed the
petition. He was single with no dependents and had no itemized
deductions in 1998, 1999, and 2001. Petitioner has not filed
Federal income tax returns for 1998, 1999, or 2001.
1 Section references are to the Internal Revenue Code as
amended and in effect for the years in issue. Rule references
are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011