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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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