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Respondent determined deficiencies in, and additions to
petitioner’s Federal income taxes as follows:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654(a)
1990 $4,439 $1,109.75 --- $290.62
1993 8,361 2,090.25 --- 350.31
1994 3,897 974.25 --- 202.21
1995 4,221 1,055.25 --- 228.86
1996 4,446 1,000.35 $844.74 236.64
1997 4,238 953.55 550.94 226.71
1998 4,161 871.65 271.18 175.84
In respondent’s answer, increased deficiencies are claimed as
follows: (1) $82 and $420, for 1990 and 1993, respectively, to
reflect petitioner’s correct filing status;1 and (2) amounts that
accrued after June 15, 2000, with respect to the additions to tax
under section 6651(a)(2) for 1996, 1997, and 1998.
After concessions, the issues for decision are: (1) Whether
petitioner is entitled to any deductions for trade or business
expenses; and (2) whether petitioner is liable for additions to
tax under sections 6651(a)(1) and 6654 for the years in issue,
and under section 6651(a)(2) for 1996, 1997, and 1998.
Background
Some of the facts have been stipulated and are so found.
1 In the notice of deficiency, respondent determined
deficiencies for 1990 and 1993 based on a filing status of
single; however, the parties stipulated that petitioner’s correct
filing status for those years is married, filing separate.
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Last modified: May 25, 2011