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By amendment to her answer, respondent asserted the following
increased amounts of deficiency and additions to tax for that
year:
Additions to Tax
Deficiency Sec. 6651(a) Sec. 6654(a)
$28,015 $5,185 $786
For the year in issue, petitioner has stipulated the amounts
of income, gain, deduction, loss, and credit properly reportable
by her and concedes her liability for the addition to tax for
failure to pay estimated tax. Accordingly, the only issue
remaining to be decided is whether petitioner is liable for the
addition to tax for failure to file timely provided by section
6651(a).1
FINDINGS OF FACT
Certain facts and the exhibits have been stipulated for
trial pursuant to Rule 91. The parties' stipulations of fact are
incorporated herein by reference and are found as facts in the
instant case. At the time the petition in the instant case was
filed, petitioner resided in Queensbury, New York.
During 1992, petitioner was married to Robert Barber. They
had three sons. At that time, Mr. Barber was the developer of a
1 Unless otherwise noted, all section references are to the
Internal Revenue Code as in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011