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Additions to Tax
Year Deficiency Section 6651(a)(1)2 Section 6654(a)
1991 $15,389 $3,847 $882
Respondent revised the determinations in the notice of
deficiency (notice), as follows:
Additions to Tax
Year Deficiency Section 6651(a)(1) Section 6654(a)
1991 $12,651 $3,163 $721
The foregoing revisions reflect respondent's concession that a
Form 1099 in the amount of $6,791.10 issued by Codega & Fricke,
Inc. (Codega & Fricke) had been erroneously reported to the
Internal Revenue Service (Service) and erroneously included in
respondent's determinations of unreported income and computations
of the deficiency and additions to tax for petitioner's taxable
year 1991.3
1(...continued)
provided by law.
2 All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
3 Respondent made the concession in a memorandum brief for
respondent (respondent's memorandum brief) filed at the Court's
request after the Court held a hearing on respondent's motion to
dismiss for failure to state a claim and for damages under sec.
6673 (respondent's motion). The Court requested respondent to
file that memorandum brief in order to respond to the allegation
in petitioner's amended petition that the Form 1099 for 1991 that
was issued to petitioner by Codega & Fricke in the amount of
$6,791.10 was erroneous. In respondent's memorandum brief, re-
spondent (1) represented that, upon investigation by respondent,
(continued...)
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Last modified: May 25, 2011