- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011