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Respondent determined deficiencies in, an addition to, and
accuracy-related penalties on, petitioners' Federal income tax
for taxable years 1990 and 1991 as follows:
Addition to Tax Accuracy-Related
Penalty
Sec. Sec.
Year Deficiency 6651(a) 6662(a)1
1990 $7,594 $1,730.75 $1,518.80
1991 44,731 -- 8,946.20
1 The first page of the statutory notice of deficiency
mistakenly refers to the accuracy-related penalties determined in
1990 and 1991 as pursuant to sec. 6651; however, the explanation
pages of the notice of deficiency refer to the correct section,
6662(a).
For the reasons discussed below, the Court will grant
respondent's motion.
FINDINGS OF FACT
At the time the petition in this case was filed, petitioners
resided in Concord, California. Petitioners requested San
Francisco, California, as the place for trial at the time they
filed their petition.
On September 21, 1994, respondent issued a statutory notice
of deficiency to petitioners for tax years 1990 and 1991. The
deficiencies at issue are attributable to respondent's
determination that (1) petitioners failed to report gross
receipts; (2) petitioners failed to report a taxable IRA
distribution and are liable for additional tax on an early
distribution from the IRA; (3) petitioners are liable for
additional self-employment tax; (4) petitioners have not
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