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for failure to pay estimated tax of $192.19.4 The notice of
deficiency did not determine an addition to tax under section
6651(a)(2) for failure to pay tax.
The deficiency in income tax is based on respondent’s
determination that in 2001 petitioner received, but failed to
report on an income tax return for that year, wages in the amount
of $38,340 from Cerritos Community College. See United States v.
Romero, 640 F.2d 1014, 1016 (9th Cir. 1981). The addition to tax
under section 6651(a)(1) is based on respondent’s determination
that petitioner failed to file a valid income tax return for
2001. See Cabirac v. Commissioner, 120 T.C. 163, 169-170 (2003);
Williams v. Commissioner, 114 T.C. 136 (2000); Beard v.
Commissioner, 82 T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th
Cir. 1986); Coulton v. Commissioner, T.C. Memo. 2005-199; Frey v.
Commissioner, T.C. Memo. 2004-87 n.6. The addition to tax under
section 6654(a) is based on respondent’s determination that
petitioner, having avoided any withholding of tax from his wages,
failed to pay estimated tax.
Petitioner received the notice of deficiency but did not
file a petition for redetermination with the Tax Court. See sec.
6213(a).
4 Attached to the notice of deficiency was a Form 4549,
Income Tax Examination Changes. The Form 4549 reflected
statutory interest under sec. 6601 computed through June 28,
2003.
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