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filed a notice of objection to petitioner's motion for summary
judgment. On December 26, 1995, petitioner filed a reply to
respondent's objection to petitioner's motion for summary
judgment.
Respondent determined deficiencies in petitioner's Federal
income tax for years 1990 and 1991 in the respective amounts of
$44,086 and $26,406. Respondent also determined an addition to
tax and an accuracy-related penalty for tax year 1990 in the
amounts of $3,799 and $330 pursuant to sections 6651(a)(1) and
6662(b)(1), respectively.
Background
The deficiencies at issue are attributable to respondent's
determination that: (1) Petitioner failed to report income for
tax years 1990 and 1991, (2) petitioner failed to substantiate
deductions for unreimbursed employee expenses for tax years 1990
and 1991,2 and (3) petitioner's deduction for exemptions should
have been reduced because his adjusted gross income was in excess
of $125,000 for tax year 1991. The additions to tax at issue are
attributable to petitioner's late filing of his 1990 Federal
income tax return and an accuracy-related penalty for negligence
for tax year 1990.
2 This adjustment results in a further adjustment because
petitioner's itemized deductions are less than the standard
deduction allowable; accordingly, respondent disallowed the
remaining itemized deductions and allowed petitioner the standard
deduction.
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