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Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency1 6651(a)(1) 6653(a)(1) 6653(a)(2) 6661(a)
1982 $213,658 $53,415 $10,683 2 $53,415
1983 38,594 9,648 1,930 3 9,135
1984 27,901 6,975 1,395 2 6,975
1985 24,166 6,042 1,208 2 6,042
Sec. Sec.
6653(a)(1)(A) 6653(a)(1)(B)
1986 4,333 1,083 $217 2 --
1Of these amounts, $102 for 1983, $1,587 for 1985, and $438 for 1986 are self-
employment taxes under ch. 2; the remainders are income taxes under ch. 1.
250 percent of the interest due on the entire deficiency for each year.
350 percent of the interest due on $36,540.
After concessions by both sides,2 the issues for decision
are as follows:
(1) Whether a notice of deficiency for 1982 through
1984 was mailed to petitioner at his last known address
within the time limitation prescribed under section 6501.
(2) Whether petitioner had unreported Schedule C gross
receipts for 1982, and, if so, in what amount.
(3) Whether petitioner had unreported interest income
for 1984 through 1986, and, if so, in what amounts.
2Respondent conceded the additions to tax for 1982 and the
$10,329 royalty income adjustment for 1982. Respondent also
conceded $158,355 of the Schedule C gross receipts adjustment to
income for 1982. Petitioner conceded that he is entitled to
claim an exemption for only one child for 1983. Deemed
concessions are discussed infra, in connection with the issues to
which the specific concessions relate.
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