-2-
Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1)16653(a)(1)6653(a)(1)(A) 6653(a)(2) 6653(a)(1)(B) 6654
1982 $20,599 $5,150 $1,030 -- * -- $2,005
1983 26,771 6,693 1,339 -- * -- 1,638
1984 29,989 7,497 1,499 -- * -- 1,885
1985 17,418 4,354 871 -- * -- 998
1986 14,821 3,705 -- $741 -- * 717
1987 16,221 4,055 -- 811 -- * 871
* 50 percent of the interest due on the portion of the underpayment
attributable to negligence. Respondent determined that the entire
amount of the underpayment was attributable to negligence.
Respondent determined the following deficiencies in, and addi-
tions to, the tax of petitioner Gayle R. Martinez (Ms. Martinez)
for the years indicated:
Additions to Tax
Sec. Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1)6653(a)(1) 6653(a)(1)(A) 6653(a)(2) 6653(a)(1)(B) 6654
1982 $20,599 $5,150 $1,030 -- * -- $2,005
1983 23,433 5,858 1,172 -- * -- 1,434
1984 25,718 6,429 1,286 -- * -- 1,617
1985 12,745 3,186 637 -- * -- 730
1986 9,655 2,414 -- $483 -- * 467
1987 10,834 2,708 -- 542 -- * 582
* 50 percent of the interest due on the portion of the underpayment
attributable to negligence. Respondent determined that the entire
amount of the underpayment was attributable to negligence.
We must decide whether respondent's determinations for each
of the years at issue should be sustained. We hold that they
should.
Background
Some of the facts were orally stipulated and are so found.
1 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011