- 2 - 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...)Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011