Rita Grant Ndirika, (2004)
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Rita Grant Ndirika, (2004)
T.C. Memo. 2004-250
UNITED STATES TAX COURT RITA GRANT NDIRIKA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10008-03. Filed November 3, 2004.Rita Grant Ndirika, pro se. Roger W. Bracken, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: Respondent determined the following deficiency in, and additions to, petitioner's Federal income tax (tax) for her taxable year 2000:Additions to Tax Year Deficiency Sec. 6651(a)(1)1Sec. 6651(a)(2) Sec. 6654(a) 2000 $76,851 $10,472.40 $4,421.68 $2,322.15In respondent's answer, respondent conceded the addition to tax under 6651(a)(2) for petitioner's taxable year 2000 and alleged an increase for that year in the addition to tax under section 6651(a)(1).The issues remaining for decision are: (1) Are certain payments that petitioner received from Gardner, Carton & Douglas (GC&D or firm) during 2000 excludable under section 104(a)(2) from petitioner's gross income for that year? We hold that they are not. (2) Is petitioner liable for 2000 for the addition to tax under section 6651(a)(1)? We hold that she is. (3) Is petitioner liable for 2000 for the addition to tax under section 6654(a)? We hold that she is to the extent stated herein.FINDINGS OF FACT Most of the facts have been stipulated and are so found. Petitioner resided in Lanham, Maryland, at the time she filed the petition in this case.During the period that began around 1995 and tha...See the full content of this document
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