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Accuracy-Related
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1991 $15,983 $2,693 $3,196
1992 8,798 -- 1,760
Unless otherwise indicated, 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.
After settlement, the issues for decision in these
consolidated cases are: (1) Whether petitioner may exclude from
gross income a $37,767 bonus received from his employer; (2)
whether petitioner may deduct $5,433 as an investment interest
expense; (3) whether petitioner has substantiated $31,796 in
claimed business expenses; (4) whether, for 1992, petitioner is
entitled to "single" filing status; (5) whether petitioner is
subject to the alternative minimum tax; and (6) whether
petitioner is liable for the addition to tax and the accuracy-
related penalties.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in Verona,
New Jersey.
In 1988, petitioner was employed as a stockbroker by Dean
Witter Reynolds, Inc. (Dean Witter). As an inducement for and
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