Christopher Clifford Roiland - Page 3

                                        - 2 -                                         
               Respondent determined a $2,184 deficiency in petitioner’s              
          2002 Federal income tax.  Respondent also determined additions to           
          tax of $491.40 and $327.60 under section 6651(a)(1) and (2),                
          respectively.  After concessions,1 the issues for decision are:             
          (1) Whether petitioner received $12,613 of wage income, and (2)             
          whether petitioner is liable for an addition to tax under section           
               Petitioner resided in Seminole, Florida, when the petition             
          was filed.                                                                  
               In 2002, petitioner worked for the Steel Detailers, Inc.               
          (the company).  The record does not indicate the precise nature             
          of petitioner’s duties for the company although petitioner                  
          indicated that he worked with computers.  Petitioner earned                 
          $12,613 in 2002 but did not file a Federal income tax return for            
          that year.                                                                  
               Respondent issued petitioner a notice of deficiency in                 
          November 2005.  Respondent determined that petitioner had                   
          unreported income of $12,613.  Respondent also determined an                
          addition to tax under section 6651(a)(1) based on petitioner’s              
          failure to file a return.                                                   

               1 Respondent concedes that petitioner was an employee for              
          Federal income tax purposes in 2002 and, therefore, was not                 
          subject to self-employment tax.  Respondent also concedes the               
          addition to tax under sec. 6651(a)(2).                                      

Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011