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2000.1 After concessions,2 the issues for decision are: (1)
Whether respondent must prepare a substitute for return compliant
with section 6020(b) as a prerequisite to issuing a notice of
deficiency; (2) whether petitioner received Social Security
payments of $14,538; (3) whether petitioner is entitled to
certain deductions; and (4) whether petitioner is liable for
additions to tax under sections 6651(a)(1) and 6654(a).
FINDINGS OF FACT
At the time the petition was filed, petitioner resided in
Camarillo, California. Petitioner is a retired airline pilot.
During 2000, petitioner received pension distributions of
$66,189 from the Northern Trust Co., Social Security payments of
at least $13,876, and interest income of $184 from Camarillo
Community Bank.
Petitioner did not file a Federal income tax return for
2000, nor did he make estimated tax payments during the year.
Respondent reconstructed petitioner’s income for 2000 using
1 All section references are to the Internal Revenue Code
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure. Amounts are rounded to the nearest
dollar.
2 Respondent concedes that: (1) Petitioner did not receive
interest income of $2,013 from the State Controller’s Office of
the State of California; and (2) petitioner is not liable for an
addition to tax under sec. 6651(a)(2). In his posttrial brief,
respondent also concedes that only $17.80 of $89 in royalties
petitioner received as executor of his father’s estate is taxable
to petitioner. Petitioner does not contest this amount.
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