Robert D. Mueller - Page 2




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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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