- 2 - We must decide the following issues with respect to 1989: 1. Whether petitioner failed to report $66,851 of wages paid to him by his wholly owned corporation. 2. Whether petitioner may deduct mortgage interest in an amount greater than allowed by respondent in the notice of deficiency. 3. Whether petitioner is liable for the addition to tax for late filing determined by respondent under section 6651(a)(1). 4. Whether petitioner is liable for the accuracy-related penalty determined by respondent under section 6662(a). We hold for respondent on all issues. Section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and exhibits submitted therewith are incorporated herein by this reference. Petitioner resided in Los Angeles, California, when he petitioned the Court. Petitioner did not file a 1989 Federal income tax return until August 2, 1993. Petitioner's 1989 tax return (Form 1040, U.S. Individual Income Tax Return), which was prepared by Nugit & Licker, C.P.A.'s on July 7, 1993, reported that petitioner received $54,250 of gross receipts from his solePage: Previous 1 2 3 4 5 Next
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