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Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654
1986 $17,266 $1,024 $38
1989 49,636 9,290 2,325
1990 22,592 2,353 523
1991 125,283 26,569 5,992
1992 56,316 12,426 2,137
Following respondent's concession that petitioner is not liable
for the additions to tax under sections 6651(a)(1) and 6654 and
that petitioner actually overpaid his taxes in each of these
years, we must decide whether petitioner is entitled to refunds
greater than the amounts proffered by respondent. We hold he is
not. Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
Background
All of the facts have been stipulated and are so found. The
stipulated facts and exhibits submitted therewith are
incorporated herein by this reference. Petitioner resided in
San Juan Capistrano, California, when he petitioned the Court.
He began working for General Electric (GE) in or around 1956. He
retired from GE in 1991 and began receiving a pension in the same
year. He received payments of interest in each of the subject
years, except 1986.
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