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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority. We shall
grant respondent’s motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Bellevue, Nebraska, at the time he
filed the petition in this case.
Petitioner did not timely file a Federal income tax (tax)
return (return) for his taxable year 1999. On or about April 25,
2002, respondent prepared a substitute for return for that year.
On September 5, 2002, respondent issued to petitioner a
notice of deficiency with respect to his taxable year 1999 (1999
notice of deficiency), which he received. In that notice,
respondent determined a deficiency in, and additions under
sections 6651(a)(1), 6651(a)(2), and 6654 to, petitioner’s tax
for that year in the respective amounts of $7,691, $1,036.57,
$598.91,3 and $204.74.
2(...continued)
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
3With respect to the addition to tax under sec. 6651(a)(2),
respondent determined in the 1999 notice of deficiency that if
petitioner “did not pay the balance of the tax owed within the
time prescribed by law, a penalty of 0.5% of the tax due is added
for each month the tax remains unpaid (not to exceed a total of
25% of the unpaid amount”.
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