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James A. Kutten, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge: Respondent determined deficiencies in
Federal individual income tax and additions to tax under sections
6651(a)(1)1 (failure to file), 6651(f) (fraud), and 66542
(underpayment of estimated tax) against petitioner as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(f) Sec. 6654
1991 $3,436 $859 -- $113
1992 3,293 823 -- 79
1993 6,374 -- $2,868 269
1 The notice of deficiency computations for the additions
to tax under secs. 6651(a)(1) and 6651(f) did not take into
account withholdings on petitioner’s wages. Sec. 6651(b)(1).
Respondent concedes that (1) the additions to tax due under sec.
6651(a)(1) for 1991 and 1992 are in the amounts of $737 and $738,
respectively, and not in the amounts of $859 and $823, as
determined in the notice of deficiency; and (2) the addition to
tax due under sec. 6651(f) for 1993 is $2,239, and not $2,868 as
determined in the notice of deficiency.
Unless indicated otherwise, all section references are to
sections of the Internal Revenue Code of 1986 as in effect for
the years in issue.
2 The notice of deficiency computation for the addition
to tax under sec. 6654 also apparently failed to take into
account withholdings on petitioner’s wages. Sec. 6654(g). The
Rule 155 computation is to take into consideration withholdings
from petitioner’s wages, in computing this addition to tax.
Unless indicated otherwise, all Rule references are to the
Tax Court Rules of Practice and Procedure.
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