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each year in issue.5 Accordingly, we need not address
respondent’s alternative arguments that petitioner is liable for
section 6651(a)(1) additions to tax or section 6662 accuracy-
related penalties.
To reflect the foregoing,
Decision will be entered
under Rule 155.
5 Schedules attached to the notice of deficiency indicate
that for each year in issue, respondent determined the sec.
6651(f) additions to tax based on petitioner’s total corrected
tax liability, calculated as the sum of the total tax shown on
petitioner’s return plus the amount determined to be a deficiency
for each year, with adjustments for additions to tax previously
assessed under sec. 6651(a)(2). Our jurisdiction over
respondent’s determination under sec. 6651(f) extends only to so
much of the addition to tax as is attributable to the deficiency.
Cf. Estate of Forgey v. Commissioner, 115 T.C. 142, 146 (2000);
Estate of Nemerov v. Commissioner, T.C. Memo. 1998-186. In the
Rule 155 computations, we expect the amount of the deficiency for
each year in issue to be calculated by including only those
amounts of the sec. 6651(f) additions to tax that are
attributable to the deficiencies for the years in issue.
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