STEELE v. COMMISSIONER

Docket No. 29459-82.

47 T.C.M. 956 (1984)

T.C. Memo. 1984-39

David B. Steele v. Commissioner.

United States Tax Court.

Filed January 24, 1984.


Attorney(s) appearing for the Case

David B. Steele, pro se, Santee, Calif. William H. Quealy, Jr., for the respondent.


Memorandum Opinion

FAY, Judge:

Respondent determined a deficiency of $4,816.54 and an addition to tax under section 6653(a)1 of $240.82 in petitioner's 1980 Federal income tax. The issues are (1) whether wages received by petitioner in 1980 are taxable, and (2) whether petitioner is liable for an addition to tax for negligence.

All of the facts are stipulated and found accordingly.2

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