Suzanne F. Mottola - Page 8

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             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 failure                 





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