Eddie M. and Cynthia L. Chandler - Page 2

               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