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Additions to Tax Penalty
Year Deficiency Sec. 6651(f) Sec. 6654 Sec. 6662(a)
1989 $39,942 --- --- $7,988
1990 32,812 $24,609 $2,159 ---
1991 34,411 25,808 1,979 ---
1992 40,963 30,722 1,786 ---
In the Answer, respondent made affirmative allegations seeking
additions to tax under section 6651(a)(1)1 for each of the
4 years in issue. Respondent contends that section 6651(a)(1)
should apply alternatively for taxable years 1990, 1991, and
1992, if we decide that section 6651(f) additions to tax do not
apply for any of these years. In the Amendment to the Answer,
respondent also alleged that section 6662(a) accuracy-related
penalties should apply alternatively for 1990, 1991, and 1992 if
we decide that section 6651(f) additions to tax do not apply. At
trial, respondent moved for a penalty under section 6673.
After concessions, the issues for our consideration are:
(1) Whether petitioner is liable for tax on his income from a
veterinary practice and other sources for each of the years in
issue; (2) whether petitioner is liable for self-employment tax
for each of the years in issue; (3) whether petitioner is liable
for additional tax under section 72 in 1989 for a premature
distribution of $30,000 from an individual retirement account;
(4) whether petitioner is liable for additions to tax under
1 Unless otherwise indicated, 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.
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Last modified: May 25, 2011