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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).
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Last modified: May 25, 2011