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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: On July 6, 1998, respondent issued a notice of
deficiency to petitioner determining deficiencies in and
additions to his Federal income taxes for the years and in the
amounts as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1986 $12,067 $1,284 $165
1987 6,675 1,172 225
1988 28,231 7,058 1,816
1989 25,087 6,272 1,697
1990 32,125 8,031 2,103
1991 33,841 8,460 1,934
1992 32,282 8,071 1,408
1993 31,642 7,587 1,265
1994 23,751 4,617 928
1995 23,426 4,503 944
The issues for decision are:
(1) Whether petitioner is entitled to a filing status other
than “single” in recognition of his claim that he has an
“economic partnership” with a same-sex individual with whom he
resided from 1989 to 1996; (2) whether petitioner is liable for
the additions to tax determined by respondent under section
6651(a)(1); and (3) whether petitioner is liable for the
additions to tax determined by respondent under section 6654. We
hold for respondent on all issues.
Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
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