Rodney L. Burr - Page 2




                                        - 2 -                                         
                                              Additions to Tax                        
                                        Sec.           Sec.      Sec.                 
               Year      Deficiency     6651(a)(1)  6651(a)(2)   6654(a)              
               1995      $10,058        $1,683.22   $1,122.15    $392.77              
               1996      11,475         1,775.47      710.19     403.50               
          Unless otherwise noted, all section references are to the                   
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               After concessions, we must decide the following issues:                
               (1) Whether petitioner has an overpayment for 1995 and, if             
          so, whether such overpayment may be used as a credit against his            
          1996 tax liability;                                                         
               (2) Whether petitioner is liable for additions to tax under            
          section 6651(a)(1) and (2); and                                             
               (3) Whether petitioner is liable for additions to tax under            
          section 6654.                                                               
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, together with the exhibits attached               
          thereto, is incorporated herein by this reference.  At the time             
          the petition was filed, petitioner resided in Elkton, Maryland.             
               Petitioner did not file timely Federal income tax returns              
          for 1994, 1995, or 1996, nor request any extensions of time to              
          file with respect to those years.  On April 19, 1999, respondent            
          issued separate statutory notices of deficiency for petitioner’s            
          1995 and 1996 tax years.  Respondent’s determinations were based            





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