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Additions to Tax Penalty
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6662(a)
1992 $10,407 $1,961 $1,961 $2,081
1993 12,378 2,284 1,675 2,476
1994 1,054 100 88 9
1995 1,496 337 67 299
In his answer, respondent asserted a claim for increased
additions to tax under section 6651(a)(1)1 of $218, $253, $109,
and $37 for 1992, 1993, 1994, and 1995, respectively.
After concessions,2 we must decide the following issues:
(1) Whether petitioner is entitled to casualty loss
deductions during the years 1992 through 1995 for the loss of a
“nonviable fetus”. We hold he is not.
(2) Whether petitioner is liable for additions to tax under
section 6651(a)(1). We hold he is.
(3) Whether petitioner is liable for accuracy-related
penalties under section 6662(a). We hold he is.
1 Unless otherwise noted, 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.
2 The parties have stipulated that petitioner received
unreported unemployment compensation during 1994 of $6,110. In
addition, respondent has conceded that petitioner is not liable
for additions to tax under sec. 6651(a)(2) for failure to pay for
any of the years in issue. Finally, respondent concedes that
petitioner is entitled to mortgage interest deductions for the
years 1992 through 1995 of $4,158, $5,644, $4,437, and $4,384,
respectively, to the extent those deductions exceed the standard
deductions for the years in issue.
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Last modified: May 25, 2011