Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651 6653(a) 6654 6661
1984 $8,723 $2,174 1$444 --- $2,181
1985 7,871 1,929 1406 --- 1,968
1986 10,899 2,678 1548 --- 2,725
1987 20,519 5,130 --- --- ---
1988 52,421 8,158 --- 3,353 ---
1990 11,351 2,838 --- 747 ---
1991 18,310 4,578 --- 1,053 ---
1 Plus 50 percent of the interest due on the deficiency.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years before
the Court, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
The issue to be decided is whether petitioner's remittance
in the form of a check in the amount of $19,789.96, sent to the
Internal Revenue Service with petitioner's 1988 Form 4868,
Application for Automatic Extension of Time to File U.S.
Individual Income Tax Return, on or about April 15, 1989, was a
payment of tax or a deposit in the nature of a cash bond.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits attached thereto are
incorporated herein by this reference.
Petitioner resided in Greeneville, Tennessee, at the time he
filed his petition in this case. In 1984, petitioner was 38
years of age. Up to that time he had led a very sheltered and
privileged life. He had no idea what his assets were and no idea
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