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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6654
1988 $36,638 $8,960 $1,832 $2,287
1989 74,747 18,491 --- 4,995
1990 12,515 2,931 --- 730
1991 13,084 3,271 --- 752
1992 26,708 6,532 --- 1,138
1993 15,679 3,720 --- 620
These determinations were reflected in two notices of
deficiency (one for years 1988, 1989, and 1990; the other for years
1991, 1992, and 1993), each dated September 29, 1995. Subsequent
to the issuance of the notices of deficiency, the docketing of this
case, and after the joinder of issues, petitioner filed delinquent
Federal income tax returns for each of the years at issue. (The
notices of deficiency were based on income items reported by third
party sources and utilized the standard deduction.) The
delinquently filed returns incorporated the income adjustments
determined by the notices of deficiency and reported income in
excess of that contained in the notices of deficiency. The returns
also reported deductions not contemplated by the notices of
deficiency. Upon review by respondent, except for losses reported
in Schedules F, the returns were accepted as filed.
Petitioner orally sought leave to amend her petition to raise
the issue of the Schedule F losses via a conference call held on
April 11, 1997. Respondent's counsel consented to the trying of
this issue, and the trial proceeded accordingly. See Rule 41(b).
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