- -2
Additions to Tax
Year Deficiency Sec. 6651(a)(1)
1985 $6,890 $813
1986 7,080 685
1987 5,095 164
1988 3,338 51
All issues but one have been settled or conceded by the parties.1
The only issue remaining for decision is whether petitioners are
liable for additions to tax under section 6651(a)(1)2 for failure
to file timely Federal income tax returns for the years 1985
through 1987.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the exhibits attached
thereto are incorporated herein by reference.
Petitioners, husband and wife, were residents of Crestview,
Florida, at the time they filed their petition in this case.
Sometime between 1985 and the time of trial, Melton R. Boone
(petitioner) experienced brain hemorrhaging. As a result, he
could not safely drive, and his son, Melton R. Boone, Jr., drove
1 With respect to whether petitioner's civil service
retirement income is taxable, the parties agreed to be bound by
the Veterans' Administration's disability determination.
Petitioners conceded that respondent's determination of their
Schedule C income for 1985 through 1987 is correct. Finally,
petitioners conceded at trial that they are liable for the
addition to tax for failure to file a timely return under sec.
6651(a)(1) for 1988.
2 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.
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Last modified: May 25, 2011