Accuracy-related penalty
Year Deficiency Sec. 6662(a)1
1990 $658 $124
1991 17,246 3,449
1992 1,517 303
Some of the issues raised by the pleadings have been
disposed of by agreement of the parties, leaving for decision:
(1) Whether petitioner is entitled to use the filing status of
"head of household" for the taxable years 1990 and 1991, and
whether petitioner is entitled to use the filing status of
"single" for the taxable year 1992; (2) whether petitioner is
entitled to a dependency exemption for his mother for each of the
taxable years 1990 and 1991; (3) whether petitioner is entitled
to deduct on Schedule A the amounts of $5,539, $37,247.73, and
$7,823, or any part thereof, for the taxable years 1990, 1991,
and 1992, respectively; (4) whether petitioner is entitled to
Schedule C business expense deductions in the amounts of $23,505
and $7,250 for the taxable years 1991 and 1992, respectively; and
(5) whether petitioner is liable for an accuracy-related penalty
pursuant to section 6662(a) for each of the taxable years at
issue.2
1 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, unless otherwise
indicated.
2 In her Answer to Amended Petition, respondent alleged
that petitioner was liable for an addition to tax pursuant to
sec. 6651(a) for failure to timely file petitioner's Federal
income tax return for the taxable year 1990. In her trial
(continued...)
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