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Additions to Tax Under Internal
Revenue Code Sections
Year Deficiency 6651(a) 6654(a)
1991 $2,974.00 $619.75 $139.39
1992 12,553.00 3,138.25 547.45
1993 2,546.00 636.50 106.65
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions by both parties,1 the issue for decision
is whether respondent can use section 66(b) to disregard the
application of Arizona's community property laws in calculating
petitioner's 1991, 1992, and 1993 income tax liability.
Petitioner did not file an income tax return for taxable years
1991, 1992, or 1993. Respondent mailed statutory notices of
deficiency to petitioner at his last known address for the
taxable years 1991, 1992, and 1993, on April 14, 1997.
Respondent determined petitioner's income tax liability based on
a single filing status with one personal exemption, without
1Petitioner has conceded the following assignments of error.
First, that his filing status for the taxable years 1991, 1992,
and 1993 shall be married filing separately. Second, that he
received taxable unemployment compensation in the amount of
$4,810 in 1993. Third, that he is liable for additions to the
tax under secs. 6651(a) and 6654(a) for the taxable years 1991,
1992, and 1993, in amounts which will be determined based on the
outcome of these cases.
Respondent has conceded that petitioner shall be allowed to
claim two exemptions in taxable year 1992: One for himself, and
one for his son, Daniel F. Layman III.
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