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Appendix
In stipulations of agreed issues, petitioner John A. Rowe
conceded the following deficiencies in income taxes, additions to
tax, and penalties:38
Additions to Tax and Penalties
Year Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661
1987 $173,817 $130,363 1 $43,454
Sec. 6653(b)(1) Sec. 6661
1988 $ 53,937 $40,453 $13,484
Sec. 6651(a)(1) Sec. 6663
1989 $ 73,279 $13,792 $54,959
Sec. 6654 Sec. 6662(c)
1990 $124,891 $8,057 $24,978
150 percent of the interest due on $173,817.
In a stipulation of settled issues, respondent and
petitioner Donna L. Rowe agreed to the following disposition of
certain issues:
Ms. Rowe conceded that she is not entitled to relief from
joint liability for an $85 theft loss adjustment in 1987 and a
$6,253 income adjustment in 1990. Ms. Rowe also conceded that
she is not entitled to relief from joint liability for $48.50 of
interest income, still in dispute, which was part of a $4,847
adjustment in 1990.
Respondent conceded that Ms. Rowe is entitled to relief from
joint liability under section 6015(c) for a $6,282 rental income
38Petitioner John A. Rowe’s concessions encompass all the
determinations made by respondent in the notices of deficiency.
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