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section 6654(a) was in error. Consequently, because petitioner
failed to make any estimated tax payments for 1993, respondent's
determination on this issue is sustained.
To reflect the foregoing,
Decisions will be entered
for respondent.4
4 The total amount of stipulated income attributed to
petitioner for 1993 exceeded the amount determined in the notice
of deficiency by $4,027. Respondent did not file responsive
pleadings to increase the deficiency against petitioner for this
additional income. Accordingly, the deficiencies and additions
to tax for 1993 will be the amounts determined in the notice of
deficiency.
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Last modified: May 25, 2011