-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