Fortunato J. Mendes v. Commissioner

121 T.C. No. 19

UNITED STATES TAX COURT FORTUNATO J. MENDES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16032-95. Filed December 11, 2003. P has been continuously incarcerated since June 17, 1988. For P’s 1988 taxable year, R (1) determined a tax deficiency based upon amounts reported on information returns as having been paid to P during that year, (2) imposed the 10-percent additional tax under sec. 72(t)(1), I.R.C., and (3) determined that P was subject to additions to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C. More than 2 years after R issued the…