- 2 -
Year Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654
2001 $3,482.10 $2,630.92 $612.43
2002 1,512.23 739.31 249.55
2003 3,282.55 729.46 418.27
The issues to be decided are whether petitioner had taxable
income in the years in issue and whether petitioner is liable for
the additions to tax for those years.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
Petitioner resided in Nashua, New Hampshire, at the time
that he filed his petition.
In notices of deficiency sent to petitioner, the Internal
Revenue Service (IRS) determined from third-party payors that
petitioner had income in the amounts of $75,747, $49,512, and
$82,150 in 2001, 2002, and 2003, respectively, and that he failed
to file Federal income tax returns for each of those years. The
IRS determined tax liabilities and additions to tax under section
6651(a)(1) for late filing, section 6651(a)(2) for failure to pay
tax, and section 6654(a) for failure to make estimated tax
payments for each year.
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Last modified: May 25, 2011