- 2 -
Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6662
1988 $29,348 $6,226 $1,473 --
1989 24,951 4,988 -- $4,990
1990 17,475 3,228 -- 3,495
1991 18,416 3,480 -- 3,683
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, except as otherwise
noted. A trial was held on October 21, 1996. At trial,
petitioner (references to petitioner in the singular are to
Charles A. Dennis) testified on his own behalf. No other
witnesses were called.
Petitioners conceded that they failed to timely file their
income tax returns for the years in issue. They are accordingly
liable for the additions to tax under section 6651(a)(1) for
those years. There remain six issues to decide. They are as
follows:
(1) Whether petitioners are entitled, for the 1991 taxable
year, to a $48 deduction for bank fees incurred on an account
which produced $45 of interest income.1 Petitioners are not so
entitled.
(2) Whether petitioners must include $3,577 in income for
the 1991 tax year. Petitioners must include that amount in
income for 1991.
1 Petitioner concedes on brief that the $45 interest was
improperly excluded from his income on his 1991 return.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011