Francis M. Gagliardi - Page 2




                                        - 2 -                                         
         Additions to Tax             Penalty                                         
         Year   Deficiency   Sec. 6651(a)(1)   Sec. 6651(a)(2)   Sec. 6662            
         1999    $212,100           --                 --         $42,420             
         2000     370,017        $45,848               1           36,679             
         2001     429,787           --                 --          85,957             
              1  The sec. 6651(a)(2) addition to tax is 0.5 percent of the            
         unpaid tax liability that will be added to the tax for each                  
         month, or fraction thereof, of nonpayment, up to a maximum of 25             
         percent, based upon the liability shown on the sec. 6020(b)                  
         return, or the final determined liability, if less.                          
         Unless otherwise indicated, all section references are to the                
         Internal Revenue Code in effect for the years in issue, and all              
         Rule references are to the Tax Court Rules of Practice and                   
         Procedure.                                                                   
              In the answer, respondent conceded the section 6651(a)(2)               
         addition to tax.  Additionally, respondent alleged that the                  
         correct amounts of deficiencies in, additions to, and penalties              
         on petitioner’s Federal income tax are as follows:1                          
         Addition to Tax      Penalty                                                 
         Year     Deficiency     Sec. 6651(a)(1)     Sec. 6662                        
         1999      $207,244             --            $41,449                         
         2000       300,102          $44,899           60,020                         
         2001       429,487           69,908           85,897                         
              The issues for decision are:  (1) Whether petitioner                    
         substantiated the amounts of his claimed gambling losses for                 
         1999, 2000, and 2001; (2) whether petitioner is liable for                   
         additions to tax pursuant to section 6651(a)(1) for 2000 and                 



               1  Amounts are rounded to the nearest dollar.                          





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Last modified: March 27, 2008