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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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Last modified: May 25, 2011