- 3 - (3) whether petitioner’s filing status was single or married filing separate in 1992; (4) whether petitioner is entitled to only the standard deduction or, instead, to itemized deductions, in 1990; (5) whether petitioner is liable for the section 6651(a)(1) addition to tax for failure timely to file income tax returns for each of the 6 years at issue; and (6) whether petitioner is liable for the section 6654 addition to tax for failure to pay estimated tax for each of the 6 years involved. Additional adjustments to petitioner’s self-employment taxes and deduction for self-employment taxes are computational in nature and will be resolved by our holdings on the foregoing issues. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. To facilitate disposition of the foregoing issues, we shall first make general findings of fact and then combine our findings and opinion with respect to each issue. I. General Findings of Fact Some of the facts have been stipulated and are so found. The stipulations of the parties, with accompanying exhibits, arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011