Wesley W. and Patsie Burnett - Page 2




                                        - 2 -                                         
          determined the following deficiencies and additions to tax for              
          Wesley W. Burnett (Mr. Burnett):2                                           
                                             Additions to Tax                         
                                   Sec.      Sec.      Sec.                           
          Year  Deficiency   6651(a)(1)   6654     6651(f)                            
          1994      $649         $49       —0-       -0-                              
          1995    13,019         -0-      $706    $9,764                              
               1996    12,923         —0-       688     9,692                         
               1997    12,778           —0-       684     9,584                       
          Respondent determined the following deficiencies and additions to           
          tax for Patsie Burnett (Ms. Burnett):3                                      
                                             Additions to Tax                         
                                   Sec.      Sec.      Sec.                           
          Year  Deficiency   6651(a)(1)   6654     6651(f)                            
          1994      $649         $49       —0-       -0-                              
          1995     7,832         -0-      $425    $5,874                              
               1996     7,719         —0-       411     5,785                         
               1997     7,591           —0-       406     5,693                       
               In the answer, respondent conceded that neither petitioner             
          is liable for the additions to tax under section 6651(f) and                
          alleged that they are liable under section 6651(a) for additions            
          to their 1995, 1996, and 1997 taxes.  Respondent alleged that the           
          additions to the respective years’ taxes under section 6651(a)              
          are $3,255, $3,231, and $3,195 for Mr. Burnett and $1,958,                  
          $1,930, and $1,898 for Ms. Burnett.                                         


               2 Section references are to applicable versions of the                 
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.  Dollar amounts are rounded to             
          the nearest dollar.                                                         
               3 The difference between the amounts shown for each                    
          petitioner is related to the computation of self-employment tax.            




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