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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined the following deficiencies and
additions to tax with respect to petitioner’s Federal income
taxes:
Additions to Tax
Taxable Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654(a)
1995 $5,881 $682 ---- $148
1996 6,483 767 $409 165
After concessions, the sole issue remaining for decision is
whether petitioner is liable for the various additions to tax
determined by respondent.1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Verbank, New York, on the date the petition was filed in this
case.
Petitioner suffered from prostate cancer and received
medical treatments relating thereto starting in 1990. In 1995,
1Petitioner concedes all other adjustments in the statutory
notices of deficiency. The parties stipulated to certain items
of income received by petitioner. With one exception, this
income is reflected in the notices of deficiency. The exception
is a State income tax refund of $131 which is includable in
petitioner’s gross income in 1995. In addition, respondent
concedes that petitioner is entitled to deductions not reflected
in the notices--to alimony deductions of $7,700 for 1995 and
$18,800 for 1996, and to deductions (subject to the adjusted
gross income limitation of sec. 213(a)) for medical expenses of
$9,284 in 1995 and $11,460 in 1996.
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