Ronnie F. Judy, (1997)

Extract

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Ronnie F. Judy, (1997)

T.C. Memo. 1997-232

UNITED STATES TAX COURT RONNIE F. JUDY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12203-94. Filed May 20, 1997.

Ronnie F. Judy, pro se.

Bonnie L. Cameron, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION BEGHE, Judge: Respondent determined deficiencies in petitioner's Federal income tax and penalties for taxable years 1989 and 1990 as follows:1 Penalty Year Deficiency Sec. 6662 1989 $6,313 $1,263 1990 17,439 3,488 After concessions by both parties, the issues for decision are: (1) Whether petitioner failed to report income for 1989 and 1990 in the amounts of $7,439 and $36,663, respectively; and (2) whether petitioner is liable for negligence penalties under section 6662(a). We hold for respondent on both issues.

FINDINGS OF FACT Some of the facts have been stipulated and are so found.

The stipulations of fact and attached exhibits are incorporated by this reference. At the time the petition was filed, petitioner's legal residence was in Reevesville, South Carolina. During the years at issue petitioner operated a farm. The primary sources of petitioner's income were sales of cattle, soybeans and grain. Petitioner maintained a single bank account at the First Federal Savings & Loan of Walt...

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