June Cordes, et al. - Page 51




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                    2.   Respondent determined petitioner was allowed a               
                         deduction for 1989 for the standard deduction, in            
                         the amount of $2,600.  Petitioner did not dispute            
                         this determination, and we deem petitioner to have           
                         conceded this adjustment.                                    
               B.   1990:                                                             
                    1.   Respondent determined petitioner was allowed a               
                         deduction for 1990 for a personal exemption in the           
                         amount of $2,050.  Petitioner did not dispute this           
                         determination, and we deem petitioner to have                
                         conceded this adjustment.                                    
                    2.   Respondent determined petitioner was allowed a               
                         deduction for 1990 for the standard deduction, in            
                         the amount of $2,725.  Petitioner did not dispute            
                         this determination, and we deem petitioner to have           
                         conceded this adjustment.                                    
          IV. Docket No. 3305-96, June J. Cordes:                                     
               A.   1991:                                                             
                    1.   Respondent adjusted petitioner’s income for 1991             
                         to reflect her receipt of taxable Social Security            
                         benefits in the amount of $2,088.  Petitioner                
                         concedes this adjustment.                                    
                    2.   Respondent determined petitioner received interest           
                         income for 1991 in the amount of $33,000.                    
                         Respondent concedes this adjustment.                         
                    3.   Respondent determined petitioner was allowed a               
                         deduction for 1991 for the standard deduction, in            
                         the amount of $3,500.  Petitioner disputed this              
                         determination in her petition but presented no               
                         further argument.  We deem petitioner to have                
                         conceded this adjustment.                                    
                    4.   Respondent determined petitioner was liable for an           
                         addition to tax for 1991, pursuant to sec.                   
                         6651(a)(1), for failure timely to file a tax                 
                         return.  Petitioner concedes she did not file an             
                         income tax return for 1991 and concedes that, if             
                         the Court concludes petitioner received income for           
                         1991, she is liable for the addition to tax to the           
                         extent of that income.                                       
                    5.   Respondent determined petitioner was liable for an           
                         addition to tax for 1991, pursuant to sec. 6654,             
                         for failure to make estimated tax payments.                  
                         Petitioner presented no argument regarding the               
                         addition to tax and concedes that, if the Court              
                         concludes petitioner received income for 1991, she           
                         is liable for the addition to tax to the extent of           
                         that income.                                                 






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