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Additions to Tax
Year Deficiency Sec. 6651(a)(1)2 Sec. 6654
1986 $11,553 $2,888.25 $558
1988 15,174 2,956.50 731
1990 15,187 3,189.25 997
1991 25,369 5,342.25 967
The issues remaining for decision are:3
(1) Is petitioner entitled to a net operating loss
deduction for each of the years at issue that is attributable to
an alleged net operating loss carryover from his taxable year
1985? We hold that he is not.
(2) Is petitioner liable for each of the years at issue for
the addition to tax under section 6651(a)(1)? We hold that he
is.
(3) Is petitioner liable for each of the years at issue for
the addition to tax under section 6654? We hold that he is.
Some of the facts have been stipulated and are so found.
Petitioner resided in Laguna Beach, California, at the time
the petition was filed.
Petitioner, who used the cash method of accounting for each
2 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
3 In the stipulation of facts in this case, petitioner conceded
all of the income determinations in the notice of deficiency
(notice) for each of the years at issue except a determination
described in the notice as a "capital gain/loss adjustment" in
the amount of $45. At trial, petitioner presented no evidence
and made no argument about that determination, and we conclude
that he does not dispute it.
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Last modified: May 25, 2011