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Alfred J. Martin, Jr. and Amilu S. Rothhammer, Docket No. 22961-88
Addition
to tax
Year Deficiency Sec. 6659
1980 $56,771 $16,085
Alfred J. Martin, Docket No. 32146-86
Additions to tax
Year Deficiency Sec. 6651 Sec. 6653(a)(1)
1981 $14,827 $81 $1,067
1982 298 15
After concessions, the issues for decision are:
1. Whether petitioner2 authorized his name to be included
on a petition filed in this Court (docket No. 22961-88) for tax
year 1980. We hold that he did not, and thus, we will dismiss
petitioner from that case.3
2. Whether petitioner is liable for the addition to tax
for failure to timely file his 1981 return under section 6651(a).
We hold that he is.
3. Whether petitioner is liable for the addition to tax
for negligence for 1981 and 1982 under section 6653(a)(1). We
hold that he is.
2 References to petitioner are to Alfred J. Martin.
Section references are to the Internal Revenue Code in effect for
the years in issue. Rule references are to the Tax Court Rules
of Practice and Procedure.
3 Consequently, we lack jurisdiction to decide whether the
time for respondent to assess petitioner’s 1980 tax liability has
passed.
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