-2-
Additions to Tax Accuracy-related Penalty
Year Deficiency Sec. 6651(a)(1)1Sec. 6654(a) Sec. 6662
1991 $6,451 $573.22 $94.66 $1,269.20
1992 3,965 418.10 42.37 793.00
1993 5,693 744.22 87.69 1,105.60
1994 19,283 4,024.75 797.35 3,856.60
1995 3,760 -- -- 752.00
The only issue remaining for decision is whether petitioners
are entitled to deduct for 1993, 1994, and 1995 certain claimed S
corporation losses.2
Background
Some of the facts have been stipulated and are so found.
Petitioners resided in Rolla, Missouri, when they filed the
petition in this case.
During the years at issue, petitioner Xavier J.R. Avula (Mr.
Avula) was employed at the campus of the University of Missouri
located in Rolla, Missouri. During those years, petitioner
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rules references are to the
Tax Court Rules of Practice and Procedure.
2In the parties’ stipulation of facts and first supplemental
stipulation of facts, petitioners conceded certain determinations
in the notice of deficiency (notice). At the commencement of the
trial in this case, petitioner Xavier J.R. Avula informed the
Court that the only issue remaining for decision in this case
relates to the claimed S corporation losses. Petitioners pre-
sented no evidence and make no argument about, and do not other-
wise dispute, the remaining determinations in the notice that
have not been conceded by them in the parties’ stipulation of
facts and supplemental stipulation of facts. We conclude that,
except for the additions to tax determined under sec. 6654(a),
petitioners have abandoned contesting those other determinations.
See Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988). As to
the additions to tax determined under sec. 6654(a), this Court
has no jurisdiction over such determinations. See sec.
6665(b)(2).
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011