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Addition to tax Addition to tax
Taxable Year Deficiency Sec. 6651(a)(1) Sec. 6654
1990 $5,917 $1,479 $387
1994 4,425 939 191
1996 4,093 1,023 218
After concessions,2 the only remaining issues for decision
are:3 (1) Whether petitioner received unreported income during
1990, 1994, and 1996 of $25,838, $30,243, and $29,812,
respectively; (2) whether petitioner is liable for additions to
tax for failure to file Federal income tax returns for 1990,
1994, and 1996; and (3) whether petitioner is liable for
additions to tax for failure to make sufficient estimated tax
payments in 1990, 1994, and 1996.
Some of the facts have been stipulated, and the stipulations
are incorporated herein by this reference. Petitioner resided in
Lawton, Oklahoma, at the time the petition was filed.
During 1990, petitioner received commissions of $17,516, a
pension of $3,433, unemployment compensation of $4,065, dividends
of $20, and wages of $804. During 1994, petitioner received
unemployment compensation of $2,450, dividends of $46, and wages
of $27,747. During 1996, petitioner received a pension of
2Petitioner did not dispute, nor did he present evidence
regarding, respondent’s determination that petitioner had self-
employment income in 1990 of $17,516 and was liable for self-
employment tax on that income. This adjustment is deemed
conceded in accordance with Rule 34(b)(4).
3The only other issues raised in the notices of deficiency
are computational.
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Last modified: May 25, 2011