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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 exhibits
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