- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011