- 2 - Additions to tax Deficiency Sec. 6651(a) Sec. 6653(a)(1) Sec. 6661 $31,101 $7,697 $1,766 $7,775 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. In an amendment to petition, petitioner alleged that the income reported on his 1988 return should be reduced by $27,992 because he erroneously reported interest income that was earned on funds that belonged to his wholly owned corporation, N.A. Tours, Inc. In an amendment to answer to amendment to petition, respondent asserted that an increased deficiency for 1988 arose from (1) unreported income from theft of $986,856, dividend income of $20,641, capital gains from real estate sales of $107,021, and ordinary income from those sales of $2,638; and (2) a change in petitioner’s filing status from single to married filing separately. Respondent further asserted that the additions to tax determined in the notice of deficiency under sections 6651(a), 6653(a)(1), and 6661 for 1988 should apply to the increased deficiency.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011