Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1989 and 1990, as well as an addition to tax and a penalty, as follows: Addition to Tax and Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1989 $3,132 --- $626 1990 4,521 $541 $904 After a concession by petitioners,2 the issues for decision are as follows: (1) Whether petitioners or respondent bears the burden of proof with respect to respondent's deficiency determinations; (2) whether petitioners understated their income on their 1989 and 1990 income tax returns by $11,149 and $15,236, respectively; (3) whether petitioners are liable for an addition to tax for failure to timely file under section 6651(a)(1) for 1990; and (4) whether petitioners are liable for an accuracy-related penalty for negligence under section 6662(a) for 1989 and 1990. Finally, whether petitioners are liable for self-employment taxes for 1989 and 1990 (and if so, the correlative amount of the Practice and Procedure. 2 Neither at trial nor on brief did petitioners contest respondent's determination that they received unreported interest income in the amount of $67 from Family Savings Federal Credit Union in 1989. Accordingly, petitioners are deemed to have conceded this adjustment to their income. Murphy v. Commissioner, 103 T.C. 111, 120 (1994); Smith v. Commissioner, T.C. Memo. 1994-188, affd. without published opinion 61 F.3d 31 (11th Cir. 1995).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011