- 2 - 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 RulePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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