Wilburn C. Hall, Jr. - Page 69

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        income, without any of the breakdowns required by the tax forms.              
        See sec. 6011; see Emmons v. Commissioner, 92 T.C. 342, 348-351               
        (1989), affd. 898 F.2d 50 (5th Cir. 1990), as to the effect of the            
        late filing of petitioner's tax returns.                                      
              Petitioner did not use due care to deal with his income tax             
        obligations, and he failed to do what a reasonable and ordinarily             
        prudent person would do under the circumstances.                              
              On brief, respondent contends that for 1983 section                     
        6653(a)(2) should be applied to the entire underpayment.                      
        Respondent in the notice of deficiency determined that $2,054 of              
        the underpayment for 1983 was not due to negligence for purposes              
        of the addition to tax under section 6653(a)(2). Our examination              
        suggests that the $2,054 amount is attributable to (1) a change in            
        filing status from head of household to single, and (2) self-                 
        employment taxes.                                                             
              Respondent has not sought to amend the pleading to assert               
        this increase formally. Ordinarily, this Court will not entertain             
        an issue that has not been pleaded properly and,--absent a clear              
        and timely claim by respondent for an increased deficiency, will              
        not enter a decision in an amount greater than was determined in              
        the notice of deficiency. Estate of Petschek v. Commissioner, 81              
        T.C. 260, 271-272 (1983), affd. 738 F.2d 67, 72 (2d Cir. 1984).               
        Section 6214(a), however, grants this Court jurisdiction to                   
        determine a deficiency or addition to tax larger than that stated             
        in the notice of deficiency, if respondent claims the increased               





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