- 66 - 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.Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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