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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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Last modified: May 25, 2011