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Penalties Addition to Tax
Year Deficiency Sec. 6662(a) Sec. 6651(a)(1)
1991 $112,652 $22,530 $5,125
1992 1,746 349 -0-
Respondent subsequently conceded that petitioner is not
liable for the addition to tax under section 6651(a)(1).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
The issues for decision are: (1) Whether petitioner failed
to report interest income, taxable dividends, and capital gains
from the sale of securities on his 1991 Federal income tax
return; (2) whether a State tax refund and credit to petitioner
in 1991 are subject to Federal income tax; (3) whether petitioner
properly claimed Schedule C deductions on his 1991 and 1992
Federal income tax returns; (4) whether petitioner is permitted
to carry over net operating losses to compute his 1991 and 1992
Federal income tax liabilities; (5) whether alleged procedural
errors by respondent affect petitioner’s liability for the
deficiencies and penalties at issue; (6) whether petitioner is
liable for accuracy-related penalties under section 6662(a) for
1991 and 1992; and (7) whether petitioner is liable for a penalty
under section 6673.
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Last modified: May 25, 2011