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Additions to tax1
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
1990 $3,667 $917 $240
1991 14,457 3,614 826
1992 11,122 2,781 485
1993 9,639 2,410 404
1994 4,237 1,059 220
1995 16,721 4,180 907
1996 6,529 1,469 $653 348
1997 22,273 5,011 891 1,192
1In his answer, respondent conceded the additions to tax
under sec. 6651(a)(2) and claimed increased additions to tax
under sec. 6651(a)(1) for 1996 and 1997 of $1,632 and $5,568,
respectively.
After concessions,2 the issues for decision are (1) whether
petitioner is liable for self-employment tax for each year at
issue except 1996; (2) whether petitioner is liable for additions
to tax for failure to file returns for each year at issue
pursuant to section 6651(a)(1); and (3) whether petitioner is
liable for additions to tax for failure to make estimated tax
payments for each year at issue except 1994 and 1996 pursuant to
section 6654.
2Prior to trial, petitioner and respondent entered into a
stipulation of settled issues, wherein petitioner conceded
deficiencies, without regard to self-employment tax, of $829 for
1990, $4,222 for 1991, $2,419 for 1992, $1,841 for 1993, $5,204
for 1995, $13 for 1996, and $6,337 for 1997. The parties agree
there is no deficiency in income tax due from petitioner for
1994, without regard to self-employment tax, and that petitioner
is not liable for self-employment tax for 1996. At trial,
petitioner orally conceded that he received self-employment
income during the years at issue but asserted that he was not
liable for the self-employment tax on that income. Petitioner
also conceded all remaining matters in dispute, except for the
issues for decision in this opinion.
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Last modified: May 25, 2011