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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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