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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: Respondent determined a Federal income tax
deficiency for petitioner’s 1997 taxable year in the amount of
$13,504 and additions to tax pursuant to section 6651(a)(1) and
(2) of $2,506.27 and $2,784.75, respectively, and pursuant to
section 6654 of $585.91.1 After concessions,2 the issues for
decision are:
(1) Whether petitioner is liable for a deficiency in the
amount of $13,504 for the 1997 taxable year; and
(2) whether petitioner is liable for additions to tax under
sections 6651(a)(1) and 6654.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time this petition
was filed, petitioner resided in Reading, Pennsylvania.
Petitioner was married as of December 31, 1997.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the year in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
2 By answer, respondent conceded the sec. 6651(a)(2) penalty
and sought a correlative increase of $278.48 in the sec.
6651(a)(1) addition to tax, on grounds that the limitations
contained in sec. 6651(c)(1) no longer applied.
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