- 8 - sustain respondent's determination of a tax deficiency for 1992 of $36,284. With respect to 1993, we note that the tax deficiency determined by respondent, $38,134, is based upon gross receipts from petitioner's business or profession in the amount of $103,328. However, petitioner is deemed to have admitted receiving gross receipts of $101,558, $1,770 less than the amount determined in the notice of deficiency. Respondent concedes that the tax deficiency and additions to tax for 1993 should be based upon the gross receipts admitted by petitioner, $101,558. At the hearing of respondent's motion, respondent submitted a recomputation of the tax and additions to tax for 1993 based upon the gross receipts admitted by petitioner. Respondent's recomputation was filed as computation in support of the motion for summary judgment. Petitioner did not object to respondent's recomputation. Accordingly, in conformity with respondent's recomputation, we find that the deficiency in petitioner's tax for 1993 is $37,439. The next issue for decision is whether petitioner is liable for the addition to tax under section 6651(a)(1) for failure to file timely Federal income tax returns for 1992 and 1993. Section 6651(a)(1) imposes an addition to tax for failure to file a timely return, unless such failurePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011