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(2) whether petitioner is liable for deficiencies for the
1994 through 2001 taxable years;
(3) whether petitioner is liable for additions to tax under
section 6651(a)(1) for the 1994 through 2001 taxable years;
(4) whether petitioner is liable for additions to tax under
section 6654 for the 1994 through 2001 taxable years; and
(5) whether the Court should impose a penalty under section
6673.
FINDINGS OF FACT
Background
Petitioner did not timely file income tax returns for the
taxable years 1994 through 2000, but he eventually submitted
completed returns for those years on October 4, 2004, to the
Appeals officer assigned to his case but only after notices of
deficiency had been issued. Petitioner did not file an income
tax return for 2001.
Respondent issued to petitioner notices of deficiency on
June 4, 2003, determining income tax deficiencies and additions
to tax for taxable years 1994 through 2000. Petitioner timely
filed a petition for these years on August 28, 2003. Respondent
issued to petitioner a notice of deficiency on January 28, 2004,
determining an income tax deficiency and additions to tax for
3(...continued)
to tax as determined by respondent even though the parties have
stipulated the amounts underlying the deficiencies.
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