T.C. Memo. 2006-64
UNITED STATES TAX COURT
WAYNE CURTIS SIRON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11208-04. Filed April 4, 2006.
Wayne Curtis Siron, pro se.
Jeanne Gramling, for respondent.
WELLS, Judge: Respondent determined a deficiency in
petitioner’s 1998 Federal income tax of $3,161, a section
6651(a)(1) addition to tax for failure to file of $788.25, and a
section 6654(a) addition to tax for failure to pay estimated
income tax of $144.25. The issues to be decided are whether
petitioner is liable for the deficiency as determined by
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1As discussed below, on Nov. 18, 2005, respondent filed a
motion to show cause why proposed facts and evidence should not
be accepted as established pursuant to Rule 91(f). On Nov. 21,
2005, we granted respondent’s motion and further ordered
petitioner to file a response in compliance with Rule 91(f)(2) or
respondent’s proposed stipulations would be deemed established
and an order would be entered pursuant to Rule 91(f)(3).
Petitioner never responded to our order, and, accordingly, we
ordered the facts deemed established on Dec. 28, 2005.
respondent, whether petitioner is liable for the additions to tax
as determined by respondent, and whether petitioner is liable for
a penalty under section 6673. All section and Code references
are to the Internal Revenue Code, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
The facts in this case have been established by the Court’s
order of December 28, 2005.1 At the time of filing the petition,
petitioner resided in Blythewood, South Carolina. Petitioner was
married to Rose Siron throughout 1998.
During 1998, petitioner received compensation from FN
Manufacturing, Inc. (FN Manufacturing), of $27,011.27 and
received compensation from the State Board of Technical and
Comparative Education (the State Board) of $323. FN
Manufacturing and the State Board each issued petitioner a
1998 Form W-2, Wage and Tax Statemen