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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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