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Additions to Tax Penalty
Sec. Sec.
Year Deficiency 6651(a)(1) Sec. 6654 6662(a)
1992 $19,240 $4,810.25 -- $3,848
1993 58,255 14,564.00 $2,440.84 --
After concessions, the only issue remaining for decision is
whether petitioner is liable for the addition to tax authorized
by section 6651(a)(1)1 for the taxable year 1993 in the amount of
$13,292.2 We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner Anargyros George Mylonas resided in Houston,
Texas, at the time he filed his petition. At all times relevant,
petitioner owned and operated a nightclub (club) which he
reported for tax purposes as a Schedule C business.
During 1993 and 1994, petitioner worked long and demanding
hours at his club. In addition to operating his club, petitioner
was renovating it, performing at least some of the work himself.
Working at the club or renovating it occupied most of
petitioner's time during 1993 and 1994.
1All section references are to the Internal Revenue Code in
effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2In a stipulation of agreed adjustments, the parties have
stipulated revised tax deficiencies for the taxable years 1992
and 1993 and the amount of the addition to tax under sec.
6651(a)(1) which is at issue for 1993.
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Last modified: May 25, 2011