- 2 - Additions to Tax Year Deficiency Sec. 6651(a) Sec. 6654 1993 $3,545 -- -- 1994 11,645 $2,911 $601 1995 1,624 406 87 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,1 the issues for decision are: (1) Whether petitioners are liable for the deficiencies determined by respondent, (2) whether Marty M. Morin (Mr. Morin) is liable for an addition to tax for failing to file a Federal income tax return for 1993, (3) whether petitioners are liable for additions to tax for failing to file Federal income tax returns for 1994 and 1995, (4) whether Mr. Morin is liable for an addition to tax for failing to make estimated Federal income tax payments for 1993, (5) whether petitioners are liable for additions to tax for failing to make estimated Federal income tax payments for 1994 and 1995, and (6) whether petitioners engaged in behavior warranting the imposition of a penalty pursuant to section 6673(a). 1 Respondent concedes that petitioners did not receive any gain from the sale of real estate in 1994.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011