- 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 6651(a)(1). Background 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