Doyce D. Gentry - Page 2




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                                                  Accuracy-related                    
                              Addition to Tax       Penalty                           
               Year   Deficiency  Sec. 6651(a)(1)     Sec. 6662(a)                    
          1991    $17,939          $4,497             $3,588                          
          1992      1,395           329                379                            

               Petitioner has conceded the deficiencies.  The only issues             
          remaining for decision are the late-filing additions and                    
          accuracy-related penalties.                                                 
               We uphold respondent’s determinations of late-filing                   
          additions.  We uphold respondent’s determinations of accuracy-              
          related penalties, other than the portion of the penalty for 1991           
          attributable to petitioner’s failure to report income of a sole             
          proprietorship received during the period August 1 through                  
          November 14, 1991, which income was erroneously included on a               
          corporate return.                                                           
                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated and are so found.               
          The stipulation of facts and the related exhibits are                       
          incorporated by this reference.                                             
               Petitioner is liable for deficiencies in Federal income tax            
          for the years 1991 and 1992 in the amounts of $17,939 and $1,395,           
          respectively.                                                               
               The filing deadline for petitioner’s 1991 Federal income tax           
          return was April 15, 1992, and for petitioner’s 1992 Federal                
          income tax return was April 15, 1993.  Petitioner filed his                 




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