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Increased Additions to Tax1
Year Deficiency Sec.6651(a)(1) Sec.6654(a)
1994 $20,297 $4,553.05 -0-
1995 20,921 5,332.38 $1,126.95
1996 24,343 5,427.01 1,279.66
1 Respondent also seeks an addition to tax under sec.
6651(a)(2) from petitioner for the 1996 taxable year in an amount
equal to 0.5 percent of any unpaid portion of the deficiency in
Federal income tax for each month or fraction thereof from April
15, 1997, until the deficiency is fully paid, not exceeding 25
percent in the aggregate.
Petitioner stipulated that no estimated income taxes had
been paid during the years in issue.
Petitioner stipulated or admitted that he and his wife
received gross income in the following amounts:
Source of Income4 1994 1995 1996
Retirement pension-petitioner $28,368 $29,133 $29,925
Interest 96 3,780 1,880
Wife’s wages 55,359 51,268 66,964
Schedule C gross receipts
(including accrued income) 27,037 37,954 26,935
Schedule E rental income 2,570 4,700 3,800
Schedule F farming activities 600 1,453 1,500
Petitioner alleges that he incurred losses in his Schedule
C, E, and F activities during the taxable years 1987, 1988, 1989,
1991, 1992, 1993, 1994, 1995, and 1996.
Respondent conceded that petitioner substantiated the
following expenses and exclusions from income:
4 These amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011