Beverlee Cochrane - Page 2




                                        - 2 -                                         
                                             Additions to Tax                         
                                             Section        Section                   
               Year      Deficiency          6651(a)(1)1    6654                      
               1989      $1,724              $349           ---                       
               1990      37,975              9,494          $2,486                    
               1991      2,462               616            141                       
               1992      25,267              6,317          1,102                     
               1993      812                 189            ---                       
               The issues remaining for decision are:                                 
               (1) Have the respective periods of limitations under section           
          6501 expired with respect to petitioner’s taxable years 1989,               
          1990, 1991, and 1992?  We hold they have not.                               
               (2) Is petitioner liable for the addition to tax under                 
          section 6651(a)(1) for each of the years 1989, 1990, 1991, and              
          1992?  We hold that she is.                                                 
               (3) Is petitioner liable for the addition to tax under                 
          section 6654 for each of the years 1990, 1991, and 1992?  We hold           
          that she is to the extent stated herein.                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner, who was single during the years at issue,                  
          resided in Phoenix, Arizona, at the time the petition was filed.            
               Petitioner requested, and received, extensions of time until           
          August 15, 1990, and August 15, 1991, respectively, within which            
          to file her 1989 and 1990 tax returns and included tax payments             
          with those requests in the amounts of $390 and $1,128.25, respec-           


               1All 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.                                  





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