- 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
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