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Addition To Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)1
1990 $7,168 $1,400 $1,243
1991 3,049 17 610
1 Respondent appears to have miscalculated this penalty.
Twenty percent of the $7,168 deficiency is $1,434.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, the issues for decision are as follows:
1. Whether petitioner, pursuant to section 165(f), is
entitled to a deduction for losses purportedly incurred in
connection with a gas station and a minimarket business. We hold
that he is not.
2. Whether petitioner, pursuant to section 1244, is
entitled to a deduction for losses relating to stock he
purportedly owned in Three Del Rey, Inc. We hold that he is not.
3. Whether petitioner, pursuant to section 6651(a), is
liable for additions to tax for failure to file his 1990 and 1991
Federal income tax returns in a timely manner. We hold that he
is.
4. Whether petitioner, pursuant to section 6662(a), is
liable for accuracy-related penalties. We hold that he is.
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Last modified: May 25, 2011