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Respondent determined deficiencies, additions to tax, and
penalties as follows:
Additions to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6662(a)
1993 $16,422 $3,584.25 $591.02 ---
1995 5,591 1,393.75 --- $1,118.20
1996 2,434 466.25 --- 486.80
1997 287 --- --- 57.40
After concessions,1 the issues for decision are: (1) Whether
interest income realized upon the redemption of tax certificates
is attributable to petitioner; (2) whether petitioner is entitled
to deductions related to rental properties for tax years 1995,
1996, and 1997; (3) whether petitioner is entitled to various
deductions on Schedule A for tax year 1995; (4) whether
petitioner is entitled to head-of-household filing status for tax
year 1996; (5) whether petitioner is liable for the additions to
tax under section 6651(a)(1) for tax years 1993, 1995, and 1996;
(6) whether petitioner is liable for the addition to tax under
section 6654 for tax year 1993; and (7) whether petitioner is
1 For tax year 1993, respondent conceded that petitioner
is entitled to the filing status of married filing jointly and is
entitled to two exemptions for himself and his wife. Petitioner
conceded that he failed to report pension income of $4,925 and
wages of $16,006.
For taxable year 1995, respondent conceded that petitioner
is entitled to deduct charitable contributions of $1,651.
Respondent also conceded that petitioner is entitled to
miscellaneous itemized deductions of $2,276 on Schedule A,
Itemized Deductions, for taxable year 1997.
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