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Respondent determined the following deficiencies in and
additions to petitioner’s Federal income taxes for 1999 and 2002:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1999 $5,788 $179 $7.38
2002 6,397 1,118 142.31
The issues for decision are: (1) Whether petitioner filed
timely Federal income tax returns for 1999 and 2002, and (2)
whether petitioner is liable for additions to tax under sections
6651(a)(1) and 6654(a).
Background
The stipulated facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioner resided in Waterford,
Wisconsin.
In 1999, petitioner was employed by Jack Safro Toyota, Inc.
in car sales and earned wages totaling $39,669. In 2002,
petitioner was employed by Andrew Motor Sales, Inc. in car sales
and earned wages totaling $44,905.
Petitioner submitted to respondent Forms 1040, U.S.
Individual Income Tax Return, for 1999 and 2002. In the income
portion of both returns, petitioner entered zeros on all lines.
Petitioner reported that he had no taxable income and that no
taxes were due. Petitioner claimed a refund of $5,072.17 for
1999 and $1,925.15 for 2002, which represented the full amounts
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