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Addition to Tax Under
Year Deficiency Sec. 6651(a)(1)
2001 $1,759 $399.75
2002 1,511 369.50
Unless otherwise noted, all section references are to the
Internal Revenue Code of 1986, as in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
We must decide the following issues: (1) Whether petitioner
had unreported income in 2001 and 2002, as determined by
respondent; (2) whether petitioner is liable for additions to tax
under section 6651(a)(1) for those years; and (3) whether
petitioner is liable for a penalty under section 6673(a)(1).
FINDINGS OF FACT
Certain matters were deemed stipulated for purposes of this
case pursuant to Rule 91(f). At the time the petition was filed,
petitioner resided in Wisconsin.
During 2001 and 2002, petitioner worked at a casino operated
by the Oneida Tribe of Wisconsin and received amounts treated as
wages by the Oneida Tribe of $20,317 and $17,259 in 2001 and
2002, respectively. The Oneida Tribe of Wisconsin issued to
petitioner Forms W-2, Wage and Tax Statement, reporting the
foregoing amounts as wages in the respective years. In 2001,
petitioner received interest of $10 and a dividend of $90 from
the AAL Member Credit Union. In 2002, petitioner received a
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Last modified: November 10, 2007