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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1988 $5,621 $1,405 $359
1989 35,648 8,912 2,413
1990 5,774 1,444 380
1991 4,421 1,105 254
1992 3,765 941 165
1993 4,552 -- --
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.
Respondent has conceded that there are no deficiencies and
additions to tax for 1988, 1990, 1991, 1992, and 1993. As a
result, the issues for decision are as follows:
1. Whether petitioner failed to report $104,278 of income
in 1989. We hold that he did.
2. Whether petitioner, pursuant to section 6651(a)(1), is
liable for an addition to tax for failure to file a timely
Federal income tax return. We hold that he is liable.
3. Whether petitioner, pursuant to section 6654, is liable
for an addition to tax for failure to make estimated income tax
payments. We hold that he is liable.
FINDINGS OF FACT
Petitioner resided in Pittsburgh, Pennsylvania, at the time
his petition was filed.
On July 26, 1996, respondent, pursuant to Rule 91(f),
submitted a motion to show cause why proposed facts in evidence
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