- 2 -
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.
Respondent determined deficiencies in petitioner’s Federal
income taxes and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1988 $2,162 $ 526.00 $133.98
1989 4,238 1,059.50 286.43
1990 3,786 946.50 249.05
After concessions by the parties,1 the issues for decision
are: (1) Whether petitioner is entitled to the filing status of
married filing jointly for the purposes of determining the amount
of any liability for the 1990 taxable year; (2) whether
petitioner is entitled to deductions for expenses incurred while
working as a deckhand on a commercial fishing boat; (3) whether
petitioner is entitled to deductions related to rental real
property; (4) whether petitioner is entitled to casualty losses
1 Petitioner concedes that he received unemployment
compensation, wages, and compensation as an independent
contractor in at least the amounts determined by respondent. We
therefore deem the gross income and self-employment tax issues to
be conceded by petitioner for the years at issue.
Respondent concedes that there was a mathematical error in
the original determination as set forth in the notice of
deficiency for the 1990 taxable year because petitioner was not
given credit equal to one-half of the self-employment tax he owed
for 1990. Accordingly, the deficiency for 1990 should be reduced
by $127, with corresponding reductions in the secs. 6651 and 6654
additions to tax.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011