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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a)
1994 $60,217 $7,303.95 $6,979.33 $1,513.69
The issues remaining for decision are:2
(1) Is petitioner required to include in gross income for
1994 $170,000 paid during that year by the State of Maryland on
account of her successful prosecution of a claim for wrongful
discharge and back wages? We hold that she is.
(2) Is petitioner required to include in gross income for
1994 wages totaling $24,170 paid during that year by the State of
Maryland? We hold that she is.
(3) Is petitioner required to include in gross income for
1994 wages totaling $6,227 paid during that year by Sportland
Properties, Inc.? We hold that she is.
(4) Is petitioner required to include in gross income for
1994 interest totaling $140 paid during that year by the Bank of
Ocean City? We hold that she is.
(5) Is petitioner liable for 1994 for the addition to tax
under section 6651(a)(1)? We hold that she is.
(6) Is petitioner liable for 1994 for the addition to tax
under section 6654(a)? We hold that she is.
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2Respondent concedes that petitioner is not liable for 1994
for the addition to tax under sec. 6651(a)(2).
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Last modified: May 25, 2011