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Edward R. Stolz II, pro se.
Daniel J. Parent, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined the following
deficiencies, additions to tax, and accuracy-related penalties
with respect to petitioner’s Federal income taxes for the taxable
years 1994 and 1995:
Additions To Tax Penalty
Taxable Income Tax Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6654 6662(a)
1994 $293,460 $15,228 $58,692
1995 391,300 $19,619 21,801 78,260
After concessions, the issues remaining for decision are:
(1) Whether petitioner is liable for the section 6651(a)(1)
addition to tax for failure to timely file an income tax return
for the 1995 taxable year; and
(2) whether petitioner is liable for the section 6662(a)
accuracy-related penalty on account of negligence or substantial
understatement of income tax for the 1995 taxable year.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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