- 2 - Penalty and Addition to Tax Year Deficiency Sec. 6651(a) Sec. 6554 Sec. 6662(a) 1990 $2,284 $571 $150 -0- 1991 2,374 -0- –0- $475 1993 24,654 6,164 1,035 –0- After concessions, the issues for decision are: (1) Whether petitioner is entitled to deduct wagering losses in the amount of $19,690 for the taxable year 1991; (2) whether petitioner must include in gross income a payment in the amount of $100,000 that he received during 1993 from the Federal Bureau of Investigation (FBI) and, if so, whether he is entitled to deduct a portion of such amount as relocation expenses; (3) whether petitioner is liable for the accuracy-related penalty under section 6662(a) for the taxable year 1991; (4) whether petitioner is liable for the addition to tax under section 6651(a)(1) for failure to file a timely return for 1993; and (5) whether petitioner is liable for the addition to tax under section 6654 for failure to pay estimated income tax for the taxable year 1993. Unless stated otherwise, all section references in this opinion are to the Internal Revenue Code as in effect during the years in issue. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibitsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011