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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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Last modified: May 25, 2011