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section 6654.1 After concessions by respondent, the issues for
decision are (1) whether petitioner had unreported income for
2001 in the amounts determined by respondent, (2) whether
petitioner is liable for the addition to tax under section
6651(a)(1), (3) whether petitioner is liable for the addition to
tax under section 6654, and (4) whether the Court should impose
on petitioner a penalty pursuant to section 6673.
FINDINGS OF FACT
Some facts have been stipulated and are so found. When the
petition was filed, petitioner resided in Cottonwood, Arizona.
In 2001, petitioner received nonemployee compensation in the
total amount of $11,227.30 from Hy-Vee Inc., Carson Services,
Perkins Family Restaurants, American Home Shield Corp., and K-
Mart Corp.; wage income of $25,685 from Hoff Mechanical Inc.;
total interest income of $1,225 from Marshalltown Development
Corp., Prudential Insurance Company of America, Home Federal
Savings Bank, and an account maintained at Edward D. Jones & Co.;
and total dividend income of $3,398 from A.G. Edwards & Sons
Inc., an account maintained at Edward D. Jones & Co., and Cash
Management Trust of America-The American Funds Service Company.
Petitioner failed to file a Federal income tax return for
2001 and did not make any estimated tax payments for the 2001 tax
1 Section references are to the applicable versions of the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
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