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Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6654
1990 $14,439 $10,829 $949
1991 17,659 13,244 1,015
1992 3,725 2,794 161
1993 22,271 16,703 930
In the alternative to the section 6651(f) additions to tax,
respondent determined section 6651(a)(1) additions to tax for the
years in issue. In an amended answer, respondent adjusted the
amount of the deficiencies made in the notice of deficiency as
follows: Respondent increased the 1990 deficiency to $15,179,
decreased the 1991 deficiency to $17,511, decreased the 1992
deficiency to $3,348, and decreased the 1993 deficiency to $4,894.
For all of these years, respondent made corresponding adjustments
to the additions to tax.
Respondent determined that petitioner must include in income
unreported gross receipts from the operation of a cattle-breeding
business. Petitioner agrees that there were unreported gross
receipts from his cattle-breeding operation, but claims that a
portion of these receipts is amounts from sales of cattle belonging
to others.
Following concessions by the parties, the issues remaining to
be decided are: (1) Whether petitioner must include in income
unreported gross receipts from his cattle-breeding operation in
1990-93 in amounts determined by respondent; (2) whether petitioner
is entitled to deductions for: (a) Cash expenditures for cattle
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