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he is liable for an addition to tax pursuant to section
6651(a)(1) of $3,498.50; and (6) whether he is liable for an
addition to tax pursuant to section 6654(a) of $671.13.
For the purpose of this motion, respondent concedes the
capital gain adjustment of $60,628, and petitioner admits having
received wages of $37,323 from MCI for 1994.
Based on decreased adjusted gross income resulting from
respondent’s concessions, respondent concedes that petitioner is
entitled to an exemption in the amount of $2,450. This
adjustment is not at issue.
Respondent concedes that petitioner is entitled to a
standard deduction of $3,800 based upon “single” filing status.
This adjustment is not at issue.
Respondent concedes that petitioner is not liable for
additions to tax pursuant to sections 6651(a)(1) and 6654(a).
Conclusion
For the reasons stated herein, we find and hold that there
is no genuine issue as to any material fact remaining for
litigation in this case and that a decision may be rendered as a
matter of law.
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Last modified: May 25, 2011