- 2 - 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 aPage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007