- 2 -
5. Held, further, R’s determination of additions
to tax under sec. 6661, I.R.C., is sustained.
Samuel G. Weiss, for petitioner.
Jody Tancer and Mark A. Ericson, for respondent.
MEMORANDUM OPINION
HALPERN, Judge: By notice of deficiency dated February 26,
1993 (the notice of deficiency), respondent determined
deficiencies in income tax and additions to tax as follows:
Additions to Tax
Sec.
Sec. 6653(a)(1) Sec. Sec.
Year Deficiency6651(a)(1)or (a)(1)(A) 6653(a)(1)(B)6661
1986 $7,267 $617 $394 50% of interest$1,817
due on $7,267
1987 24,372 1,522 2,127 50% of interest6,072
due on $24,288
1988 7,632 --- 382 --- 1,908
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Each of the parties has conceded certain issues, and the
parties have agreed to the resolution of certain other issues.
The issues remaining for decision are (1) whether petitioner
failed to report certain items of gross income, (2) whether he is
entitled to certain disallowed Schedule C and Schedule A
deductions, and (3) whether he is liable for certain remaining
additions to tax. The parties have stipulated numerous facts,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011