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The amounts of the deficiencies, additions to tax, and
accuracy-related penalties that were determined by respondent in
the two notices of deficiency are as follows:
Taxable Year Deficiency Addition to Penalty
Tax Sec. 6662
Sec. 6651
1992 $41,489 $8,105 $8,298
1993 47,492 9,590 9,498
1994 54,799 --- 10,960
The adjustments to income that gave rise to the deficiencies
that were determined by respondent in the two notices of
deficiency were as follows:
Adjustments 1992 1993 1994
Const. dividends $111,953 $125,237 $139,462
Rental income 9,447 11,735 16,943
Itemized deducts. 7,297 2,584 3,184
Exemptions 3,772 3,290 2,107
Respondent issued two notices of deficiency because the
notice for the taxable year 1992 was based on a different filing
status than was the notice for the taxable years 1993 and 1994.
Thus, for the taxable year 1992, respondent determined that
petitioner's filing status was married filing separately, whereas
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Last modified: May 25, 2011