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Additions to Tax, I.R.C.
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1989 $3,274 $ 819 $221
1990 3,469 867 228
1991 3,611 903 208
1992 3,329 832 145
1993 3,180 795 133
1994 7,398 1,850 381
1995 2,772 693 151
Unless indicated otherwise, 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. The parties have stipulated that the correct
deficiencies are as follows:
Year Deficiency
1989 $2,900
1990 2,686
1991 2,860
1992 798
1993 576
1994 268
1995 0
Further, respondent conceded the additions to tax for 1994 and
1995.
The issue for decision is whether petitioner is liable for
the additions to tax under section 6651(a)(1) for failure to file
timely returns and section 6654 for underpayment of estimated tax
for each of the tax years 1989 through 1993.
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Last modified: May 25, 2011