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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: James C. Estrada petitioned this Court to
redetermine respondent's determination of the following Federal
income tax deficiencies and additions thereto:1
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654(a)
1991 $8,191 $2,048 $470
1992 7,513 1,878 327
We must decide:
1. Whether petitioner failed to report income for 1991 and
1992. We hold that he did;
2. whether petitioner is liable for the section 6651(a)(1)
addition to tax for 1991 and 1992. We hold that he is;
3. whether petitioner is liable for the section 6654(a)
addition to tax for 1991 and 1992. We hold that he is.
Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the years in issue. Rule
1 In her second amendment to answer, respondent increased
petitioner's deficiencies and additions to tax as follows:
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654(a)
1991 $35,773 $8,943 $2,059
1992 28,405 7,101 1,239
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Last modified: May 25, 2011