- 2 - Haines B. Gaffner, Deceased Addition to Tax Under Year Deficiency Sec. 6651(a)(1)1 Sec.6651(a)(2) Sec. 6654 1992 $75,428.00 $15,797.25 –- $3,289.81 1993 94,418.00 18,622.00 -- 3,028.21 1994 99,382.00 19,624.25 -- 3,952.91 1995 110,823.00 22,236.50 -- 4,691.07 1996 146,782.00 31,279.73 * 7,353.55 *The addition to tax under sec. 6651(a)(2) is calculated as .5 percent of the amount shown as tax in the tax return if the failure to pay such tax on or before the date prescribed for payment of such tax is not for more than 1 month, with an additional .5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate. Mary Ellen Gaffner Addition to Tax Under Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654 1992 $38,043.00 $6,451.00 –- $1,659.25 1993 44,705.00 6,194.00 –- 945.31 1994 48,761.00 6,968.75 –- 1,326.05 1995 49,707.00 6,957.75 –- 1,377.26 1996 190,063.00 41,017.73 * 9,657.13 *The addition to tax under sec. 6651(a)(2) is calculated as .5 percent of the amount shown as tax in the tax return if the failure to pay such tax on or before the date prescribed for payment of such tax is not for more than 1 month, with an additional .5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate. The issues remaining for decision are: 1. Do petitioners2 have rental income for 1996 in an amount that is less than the amount determined by respondent? We hold that they do not. 1All section references are to the Internal Revenue Code (Code) in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2We shall refer collectively to the petitioner in each of these consolidated cases as petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011